ASSISTANT COMMISSIONER OF INCOME TAX, CC-30, NEW DELHI, NEW DELHI vs. SEVEN SEAS HOSPITALITY PRIVATE LIMITED, NEW DELHI

ITA 2225/DEL/2025Status: DisposedITAT Delhi14 November 2025AY 2018-1912 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that for levying penalty under Section 271DA for violation of Section 269ST, it is mandatory to record satisfaction in the assessment order. Since no such satisfaction was recorded, the penalty order was quashed.

What were the facts?

During a search, the Revenue alleged unaccounted sales by the assessee. The Assessing Officer imposed a penalty under Section 271DA for alleged violations of Section 269ST. The assessee contended that no satisfaction was recorded in the assessment order for initiating penalty proceedings.

What were the issues?

Whether penalty under Section 271DA can be levied without recording satisfaction in the assessment order regarding violation of Section 269ST.

Which sections of the Income-tax Act were involved?

Section 271DA,Section 269ST,Section 271D

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Cases cited in this judgment(4)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, DELHI BENCHES : A : NEW DELHI

Before: SHRI S. RIFAUR RAHMAN & SHRI ANUBHAV SHARMA

For Appellant: Shri Anil Jain, CA &, Shri Pritam Kumar, Advocate
For Respondent: Shri Amit Jain, CIT-DR
Hearing: 10.09.2025Pronounced: 14.11.2025

PER ANUBHAV SHARMA, JM: These are appeals preferred by the Revenue against the orders dated 09.12.2024 of the Commissioner of Income-tax (Appeals)-30, New Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. ‘FAA’) in appeals No.30/10331/2017-18 and No.NFAC/2018-19/10157929 arising out of the appeals before it against the orders dated 15.06.2022 and 14.06.2022,

ITAs No.2225 & 2226/Del/2025

respectively, passed u/s 271DA of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) by the Addl.CIT, Central Range-8, New Delhi (hereinafter referred to

The order continues below.

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