← All Phrases

“satisfaction for initiation of penalty”

PenaltySection 271Section 27180 judgments

MAHAVEER SINGH,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

applicable to the present case, since in that case in the assessment order, the Ld. A.O. has not recorded the satisfaction for initiation of penalty proceedings. In that circumstances, the Chennai Tribunal held that Revision proceedings cannot be invoked, solely for the reasons that penalty proceedings initiated on a wrong

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

that the initiation and levy of\npenalty u/s 271D of the Act is not sustainable as the AO has not\nrecorded his satisfaction for initiation of penalty proceedings u/s\n271D of the Act in contravention to the provisions of section 269SS\nof the Act, in the assessment order passed ... cash received by the assessee is in\nviolation of provisions of sec.269SS of the Act, then the same\namounts to recording of satisfaction for initiation of penalty\nu/sec.271D of the Act. He has further submitted that since\nthe jurisdiction for levy of penalty u/sec.271D lies with the\nJCIT therefore

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

that the initiation and levy of\npenalty u/s 271D of the Act is not sustainable as the AO has not\nrecorded his satisfaction for initiation of penalty proceedings u/s\n271D of the Act in contravention to the provisions of section 269SS\nof the Act, in the assessment order passed ... cash received by the assessee is in\nviolation of provisions of sec.269SS of the Act, then the same\namounts to recording of satisfaction for initiation of penalty\nu/sec.271D of the Act. He has further submitted that since\nthe jurisdiction for levy of penalty u/sec.271D lies with the\nJCIT therefore

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

that the initiation and levy of\npenalty u/s 271D of the Act is not sustainable as the AO has not\nrecorded his satisfaction for initiation of penalty proceedings u/s\n271D of the Act in contravention to the provisions of section 269SS\nof the Act, in the assessment order passed ... cash received by the assessee is in\nviolation of provisions of sec.269SS of the Act, then the same\namounts to recording of satisfaction for initiation of penalty\nu/sec.271D of the Act. He has further submitted that since\nthe jurisdiction for levy of penalty u/sec.271D lies with the\nJCIT therefore

RAVI RISHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, three appeals i

ITA 972/HYD/2024[2019-20]Status: DisposedITAT Hyderabad18 Feb 2026AY 2019-20
For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

that the initiation and levy of\npenalty u/s 271D of the Act is not sustainable as the AO has not\nrecorded his satisfaction for initiation of penalty proceedings u/s\n271D of the Act in contravention to the provisions of section 269SS\nof the Act, in the assessment order passed ... cash received by the assessee is in\nviolation of provisions of sec.269SS of the Act, then the same\namounts to recording of satisfaction for initiation of penalty\nu/sec.271D of the Act. He has further submitted that since\nthe jurisdiction for levy of penalty u/sec.271D lies with the\nJCIT therefore

ACIT-CENTRAL CIRCLE-2(4), HYDERABAD vs. INCREDIBLE INDIA PROJECTS PRIVATE LIMITED, SECUNDERABAD

In the result, appeal of the Revenue is dismissed

ITA 605/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Jan 2026AY 2018-19
For Appellant: Sri Sandeep Goel, AdvocateFor Respondent: MS U Mini Chandran, CIT-DR
Section 2Section 271ASection 274

{ "clean_text": "1\nITA.No.605/Hyd./2022\nआयकर अपीलीय अधिकरण, हैदराबाद पीठ\nIN THE INCOME TAX APPELLATE TRIBUNAL\nHyderabad ‘A’ Bench

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, CENTRAL RANGE-4,, NEW DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2926/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDL. COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 04,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2925/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2924/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2923/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2922/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2921/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2920/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2919/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

Present Case In the instant case: • The Assessing Officer (AO) completed the assessment u/s 143(3) on 29.12.2022, and recorded satisfaction for initiation of penalty u/s 271E. • The AO made a reference to the Additional Commissioner of Income Tax, being the competent authority u/s 274(2), for further necessary action ... brought to our notice the relevant facts that the assessment order was completed u/s 143(3) on 29.12.2022 and recorded the satisfaction for initiation of penalty u/s 271E and also submitted that Assessing Officer made a reference to the Addl.CIT being a competent authority u/s 274(2) for further necessary

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

ITA 613/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

made the addition on account of bogus purchases after rejecting the books u/s. 145(3) of the Act. The AO specifically recorded satisfaction for initiation of penalty proceedings u/s.271(1)(c) of the Act and thereafter issued notice u/s.274 read with section

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

ITA 612/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

made the addition on account of bogus purchases after rejecting the books u/s. 145(3) of the Act. The AO specifically recorded satisfaction for initiation of penalty proceedings u/s.271(1)(c) of the Act and thereafter issued notice u/s.274 read with section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, appeal filed by the Revenue is dismissed and the\nCross-Objection filed by the assessee is allowed

ITA 1899/CHNY/2025[2021-22]Status: DisposedITAT Chennai30 Oct 2025AY 2021-22
Section 132Section 269SSection 271D

context of the present\ncase by the Ld. AR was that, the assessment order dated 30-12-2022\nwhich contained express satisfaction for initiation of penalty u/s 271D of\nthe Act was passed by the AO with the prior approval of Addl. CIT [Para\n17 / page 67 of the assessment ... Hence, if the Revenue's\nargument is upheld that, the AO, in the present case, was not competent\nto record satisfaction for initiation of penalty u/s 271D of the Act, then it\nwould lead to an absurd situation viz., there is no valid satisfaction\nrecorded prior to initiation of penalty

SARVESWARAN DEEPA,KANCHIPURAM vs. THE INCOME TAX OFFICER, NON CORP WARD 22(6), TAMBARAM, TAMBARAM

In the result, the appeal of the assessee is partly allowed

ITA 1973/CHNY/2025[2015-16]Status: DisposedITAT Chennai23 Oct 2025AY 2015-16
For Appellant: Shri. R. S. Lakshmi Narayana, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 142(1)Section 147Section 148Section 271(1)(b)Section 274

wherein the total income\nof the assessee was assessed at Rs.11,21,440/-. In the said assessment order,\nthe AO also recorded satisfaction for initiation of penalty proceedings u/s.\n271(1)(b) of the Act, on account of the assessee's failure to comply with the\nnotices issued u/s.142

BABU SINGH,GAUTAM BUDDHA NAGAR vs. ASSESSMENT UNIT, DELHI

In the result, the appeal of the assessee is allowed

ITA 3440/DEL/2025[2015-16]Status: DisposedITAT Delhi30 Sept 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalbabu Singh, Assessment Unit, 138, Village-Mirzapur, Knp-W-(100) (6), P.O.-Dankaur, Vs. Income Tax Department Distt. Gautam Buddha Nagar, Uttar Pradesh 203201. Pan-Eakps8485M (Appellant) (Respondent) Assessee By Shri Udham Singh, Adv. Department By Shri Shyam Manohar Singh, Sr. Dr Date Of Hearing 25/09/2025 Date Of Pronouncement 30/09/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Cit(A), In Short] Dated 10.03.2025 In Appeal No. Nfac/2014-15/10297028 Arising Out Of Order Passed U/S 271(1)(B) Of The Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 20.09.2023 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessment Of The Assessee Was Completed Vide Order Dated 21.03.2023 Passed U/S 147/144 R.W.S 144B Of The Act Wherein The Penalty Proceedings U/S 271(1)(B) Were Initiated For Non-Compliance Of The Statutory Notices. Thereafter, The Ao Proceeded With Pending Penalty Proceedings U/S Babu Singh Vs. Assessment Unit 271(1)(B) & In Terms Of Order Dated 20.09.2023 Levied Penalty Of Rs.20,000/- For Non-Compliance Of The Statutory Notices Issued U/S 142(1) Of The Act On 17.01.2023 & 01.02.2023. 3. Against Such Order, An Appeal Was Preferred By The Assessee Before The Ld. Cit(A) Who Vide Impugned Order Dated 10.03.2023 Has Dismissed The Appeal Of The Assessee Therefore, The Assessee Is In Appeal Before The Tribunal.

Section 142(1)Section 147Section 250Section 271(1)(b)

record. In the instant case, the assessment order passed u/s 147/144 dated 21.03.2023 ex-party wherein the AO has recorded his satisfaction for initiation of penalty proceedings u/s 271(1)(b) of the Act has been set aside by Ld. CIT(A) for fresh adjudication in terms of the order ... 250/147 r.w.s 144 of the Act and start proceedings for fresh assessment through ITBA, therefore, there remain no order under which satisfaction for initiation of penalty proceedings u/s 271(1)(b) was recorded. In view of these facts, we direct the AO to delete the penalty levied of Rs.20

BENNETT COLEMAN & CO LTD,MUMBAI vs. DCIT 1(1)(1), MUMBAI

In the result, this ground-7 of appeal is dismissed

ITA 190/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Aug 2025AY 2016-17
Section 10(38)Section 143(3)Section 144(2)Section 14ASection 14A(2)Section 250Section 43C

case and in law, the learned\nCTT (A) has erred in upholding the findings of the Ld. AO recording\npurported satisfaction for initiation of penalty proceedings against the\nAppellant?\n4.\nThe assessee is the flagship company of the ‘Times Group', India's largest\nmedia conglomerate, with operations spanning across various

Showing 1–20 of 80 · Page 1 of 4