HARI KRISHNA LEELA PRASAD PALADUGU,HYDERABAD vs. INCOME TAX OFFICER, WARD - 6(1), HYDERABAD

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

reassessment proceedings under Section 147 of the Act, and in the absence of any assessment proceedings, the question of initiation of penalty proceedings under Section 271D of the Act does not arise. Since there was no satisfaction recorded by the A.O. as required under the law, the consequent order passed by the A.O. imposing penalty under Section 271D

A Z DEVELOPERS,HYDERABAD vs. ITO., WARD-14(1), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

reassessment proceedings u/s 147 of the Income Tax Act,1961 (“the Act”). During the course of the proceedings, the learned Assessing Officer (“Ld. AO”) issued notices u/s 142(1) of the Act dated 22/12/2021, 17/01/2022 and 17/02/2022 to the assessee, to which the assessee could not respond. Consequently, the Ld. AO initiated penalty proceedings under Section