CIT v. Jai Laxmi Rice Mills

379 ITR 521Supreme Court of India2015#975 most cited

What is CIT v. Jai Laxmi Rice Mills authority for?

The assessing officer must record explicit satisfaction in the assessment order for initiating penalty proceedings under sections like 271D, 271E, 269SS, 269T, or 269ST; a mere recommendation or information to another authority is insufficient to validate the penalty.

110

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Jai Laxmi Rice Mills · penalty initiation satisfaction · recording satisfaction assessment order · Section 271D penalty · Section 271E penalty · Section 269SS penalty · Section 269ST penalty · Assessing Officer satisfaction · validity of penalty proceedings · penalty under section 269T

Sections most often in play

Section 271DSection 269SSSection 143(3)Section 271ESection 269TSection 271(1)(c)Section 273BSection 147

Issues it is cited on

penalty under section 271esatisfaction for initiation of penaltysection 275(1)(c)penalty under section 271dsection 275(1)(a)section 271esection 269tsection 275(1)section 143(l)(a)section 269stsection 269sssection 275

Judgments citing CIT v. Jai Laxmi Rice Mills

Vimal Todi, Indore vs. Additional Commissioner of Income Tax, Indore

Appeal is allowed

ITA 188/IND/2024[2012-13]Status: DisposedITAT Indore06 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

Section 132Section 254(2)Section 271DSection 275Section 275(1)(c)

…023 or 31.03.2024, whichever is later. It was pointed out that since the impugned penalty order was dated 30.05.2024 hence, it was beyond the statutory time limit. For this purpose, the Ld. AR relied on the case of Jai Laxmi Rice Mills Ambala City reported in 379 ITR 521 (SC), for the point that the date of recording of satisfaction by the Ld. AO is the material date on which the initiation of penalty has to be considered. Similar finding was pointing out in the case of Sunil Agrawal reported in 172 taxmann.com 54 (Raj.); the case of Grandhi Shri Venkata Amarendra reported in 167 taxmann.com 352 (AP); and also th…

Venkata Ramana Murthy Bollapragada, Hyderabad vs. ITO, Ward-13(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1961/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1961/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Venkata Ramana Murthy Vs. Income Tax Officer, Bollapragada, Ward-13(1), Hyderabad. Hyderabad. Pan: Abmpb7770R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 24/02/2026 घोषणा की तारीख/Date Of 26/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 27/10/2025, Which In Turn Arises From The Order Passed By The Additional/Joint Commissioner Of Income Tax, Range-13, Hyderabad Under Section 271D Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/06/2022 For The Assessment Year

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(3)Section 269SSection 271DSection 274Section 54F

…of the Act, dated 25/10/2018 had not recorded his satisfaction for initiating the penalty in the body of the assessment order, therefore, as per the binding judgment of the Hon’ble Supreme Court in the case of CIT vs. Jai Laxmi Rice Mills Ambala City, (2015) 379 ITR 521 (SC), the Additional/Joint Commissioner of Income Tax, Range-13, Hyderabad was divested of his jurisdiction to impose the penalty in the hands of the assessee vide his order under section 271D of the Act, dated 30/06/2022. 9. Per contra, Dr. Sachin Kumar, Learned Senior Departmental Representative (for short, “Ld. Sr-DR”) vehemently objected to t…

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 1301/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

…t order for initiation of penalty. He has contended that recording of satisfaction for initiating the penalty u/sec.271D is a ‘mandatory' condition as held by the Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Rice Mills, Ambala City [2015] 379 ITR 521 (SC). He has also relied upon the Order of Hon'ble Jurisdictional High Court of Andhra Pradesh in the case of Srinivasa Reddy Reddappagari, Kadapa, Andhra Pradesh vs. JСІТ, НHyderabad & Another in WP.No.44285 of 2022 dated 26.12.2022 and submitted that following the Judgment of Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Ric…

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle 2(4), Hyderabad

ITA 1300/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

…t order for initiation of penalty. He has contended that recording of satisfaction for initiating the penalty u/sec.271D is a ‘mandatory' condition as held by the Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Rice Mills, Ambala City [2015] 379 ITR 521 (SC). He has also relied upon the Order of Hon'ble Jurisdictional High Court of Andhra Pradesh in the case of Srinivasa Reddy Reddappagari, Kadapa, Andhra Pradesh vs. JСІТ, НHyderabad & Another in WP.No.44285 of 2022 dated 26.12.2022 and submitted that following the Judgment of Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Ric…

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 973/HYD/2024[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

…t order for initiation of penalty. He has contended that recording of satisfaction for initiating the penalty u/sec.271D is a ‘mandatory' condition as held by the Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Rice Mills, Ambala City [2015] 379 ITR 521 (SC). He has also relied upon the Order of Hon'ble Jurisdictional High Court of Andhra Pradesh in the case of Srinivasa Reddy Reddappagari, Kadapa, Andhra Pradesh vs. JСІТ, НHyderabad & Another in WP.No.44285 of 2022 dated 26.12.2022 and submitted that following the Judgment of Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Ric…

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 972/HYD/2024[2019-20]Status: DisposedITAT Hyderabad18 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

…t order for initiation of penalty. He has contended that recording of satisfaction for initiating the penalty u/sec.271D is a ‘mandatory' condition as held by the Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Rice Mills, Ambala City [2015] 379 ITR 521 (SC). He has also relied upon the Order of Hon'ble Jurisdictional High Court of Andhra Pradesh in the case of Srinivasa Reddy Reddappagari, Kadapa, Andhra Pradesh vs. JСІТ, НHyderabad & Another in WP.No.44285 of 2022 dated 26.12.2022 and submitted that following the Judgment of Hon'ble Supreme Court in the case of CIT, Panchkula vs. Jai Laxmi Ric…

Premji Bhurlal Gala, Mumbai vs. Addl CIT Rang 24(1), Mumbai

In the result, Assessee’s appeal is allowed

ITA 6596/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Jan 2026AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2016-17 Premji Bhurlal Gala Addl. Cit Range 24(1), B-301, Water Ford, Cd Mumbai Barfiwala Road Juhu Fally Kautilya Bhavan, C-41 To C- Vs. Andheri West, Mumbai - 43, G Block, Bandra Kurla 400058 Complex, Bandra (E) Mumbai – 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Vinod Kumar Bindal & Satish Kumar, Ld. A. Rs. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 09.12.2025 Date Of Pronouncement : 28.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 23.09.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In The Instant Case, The Case Of The Assessee Was Reopened Under Section 147 Of The Act, On The Basis Of Search & Survey Action Under Section 132 Of The Act Carried Out In The Case Of M/S. Evergreen Enterprises, Wherein The Statement Of The Partner In M/S. Evergreen Enterprises, Mr. Nilesh Bharani Was Recorded Under Section 132(4) Of The Act, Unearthing An Undisclosed Activity, 2 Premji Bhurlal Gala

For Appellant: Shri Vinod Kumar Bindal & SatishFor Respondent: Shri Virabhadra Mahajan, SR. D.R
Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 269SSection 271Section 271D

…he Act, the AO has not recorded clear cut satisfaction with regard to the initiation of the penalty proceedings under Section 271 (D) of the Act and thus, attracts the judgment of the Hon’ble Apex Court in the case of CIT vs. M/s. Jaya Laxmi Rice Mills (2015) 379 ITR 521 (SC) wherein the Hon’ble Apex Court has held as under: "In these appeals, we are concerned with the question as to whether penalty proceeding under Section 271D of the Income Tax Act (hereinafter referred to as "the Act") is independent of the assessment proceeding and this question arises for consideration in respect of Assessment Years 1991-19…

DCIT Central Circle 1 Delhi, Delhi vs. Sahara India Financial Corporation Ltd, Lucknow

ITA 4679/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Jan 2026AY 2010-11
Section 142Section 250Section 269SSection 271D

…023 or 31.03.2024, whichever is later. It was pointed out that since the impugned penalty order was dated 30.05.2024 hence, it was beyond the statutory time limit. For this purpose, the Ld. AR relied on the case of Jai Laxmi Rice Mills Ambala City reported in 379 ITR 521 (SC), for the point that the date of recording of satisfaction by the Ld. AO is the material date on which the initiation of penalty has to be considered. Similar finding was pointing out in the case of Sunil Agrawal reported in 172 taxmann.com 54 (Raj.); the case of Grandhi Shri Venkata Amarendra reported in 167 taxmann.com 352 (AP); and also th…

Hari Krishna Leela Prasad Paladugu, Hyderabad vs. Income Tax Officer, Ward - 6(1), Hyderabad

ITA 798/HYD/2025[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(1)Section 143(3)Section 269SSection 271DSection 274

…ing penalty under Section 271D of the Act, cannot be sustained. Therefore, he submitted that, the penalty levied by the A.O. should be deleted. In this regard, he relied upon the decision of Hon'ble Supreme Court in the case of CIT Vs. Jai Lakshmi Rice Mills (379 ITR 521) and also the decision of the Hon’ble High Court of Telangana in the case of Srinivasa Reddy Reddappagari Vs. Joint Commissioner of Income Tax [2023] 332 8 Hari Krishna Leela Paladugu CTR 614 (Telangana). The assessee also relied upon the decision of the ITAT, Indore Bench, in the case of Sri Umakant Sharma v. JCIT in TA Nos. 364 to 366/Ind/202…

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Seven Seas Hospitality Private Limited, New Delhi

ITA 2226/DEL/2025[2019-20]Status: DisposedITAT Delhi14 Nov 2025AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Anil Jain, CA &For Respondent: Shri Amit Jain, CIT-DR
Section 153ASection 269SSection 271DSection 274Section 275(1)(c)Section 27I

…ssment order no satisfaction has been recorded for violation of provisions of section 269ST and initiation of penalty proceeding u/s 27IDA which is very much required as per the judgement of the Hon'ble Supreme Court in the case of CIT vs Jai Laxmi Rice mills 379 ITR 521. 5. Without prejudice to the above it was also submitted that in the working chart of alleged cash receipt provided by the Ld. JCIT vide letter dated 13.05.2022, there are various duplicate entries, transactions not materialized, transactions does not pertain to sales transaction are pertains to earlier period and it was also stated that this pro…

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Seven Seas Hospitality Private Limited, New Delhi

ITA 2225/DEL/2025[2018-19]Status: DisposedITAT Delhi14 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Anil Jain, CA &For Respondent: Shri Amit Jain, CIT-DR
Section 153ASection 269SSection 271DSection 274Section 275(1)(c)Section 27I

…ssment order no satisfaction has been recorded for violation of provisions of section 269ST and initiation of penalty proceeding u/s 27IDA which is very much required as per the judgement of the Hon'ble Supreme Court in the case of CIT vs Jai Laxmi Rice mills 379 ITR 521. 5. Without prejudice to the above it was also submitted that in the working chart of alleged cash receipt provided by the Ld. JCIT vide letter dated 13.05.2022, there are various duplicate entries, transactions not materialized, transactions does not pertain to sales transaction are pertains to earlier period and it was also stated that this pro…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1178/JPR/2025[2021-22]Status: DisposedITAT Jaipur13 Nov 2025AY 2021-22
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1176/JPR/2025[2020-21]Status: DisposedITAT Jaipur13 Nov 2025AY 2020-21
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1175/JPR/2025[2020-21]Status: DisposedITAT Jaipur13 Nov 2025AY 2020-21
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1174/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result, the appeals of the revenue stands dismissed, and the

ITA 1170/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…o be annulled and set aside. 6.1.3 It is a well‑settled principle that penalties under Section 271D and 271E cannot be initiated without the AO first forming a satisfaction on record during the assessment proceedings. In CIT v. Jai Laxmi Rice Mills (SC 2015) 379 ITR 521, (Copy at Case laws PB Page No. 1-3) the Supreme Court held that "As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1169/JPR/2025[2018]Status: DisposedITAT Jaipur13 Nov 2025
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1168/JPR/2025[2017-18]Status: DisposedITAT Jaipur13 Nov 2025AY 2017-18
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result, the appeals of the revenue stands dismissed, and the

ITA 1167/JPR/2025[2017-18]Status: DisposedITAT Jaipur13 Nov 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…o be annulled and set aside. 6.1.3 It is a well‑settled principle that penalties under Section 271D and 271E cannot be initiated without the AO first forming a satisfaction on record during the assessment proceedings. In CIT v. Jai Laxmi Rice Mills (SC 2015) 379 ITR 521, (Copy at Case laws PB Page No. 1-3) the Supreme Court held that "As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the…

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result the appeal of the revenue in ITA no

ITA 1166/JPR/2025[2016-17]Status: DisposedITAT Jaipur13 Nov 2025AY 2016-17
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

…O considered that income and opted to levy the penalty on the other sections of the Act. Be that it so may then in that circumstance on this issue Id. AR of the assessee serviced before us the decision of Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills 379 ITR 521 wherein the Apex court has also held that; 5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar a…