MANISH SHARMA,KOTA vs. JCIT, CENTRAL CIRCLE, UDAIPUR
In the result, appeal of the assessee is allowed
ITA 619/JODH/2024[2011-12]Status: DisposedITAT Jodhpur25 Jun 2025AY 2011-12
Bench: Date Of Hearing.
Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 250Section 269TSection 271DSection 271E
269T are not related to assessment proceedings or other proceedings, during which penalty proceedings under sections 271D and 271E might have been initiated, has no relevance for sustaining or not sustaining penalty proceedings, and therefore, clause (a) of section 275(1) cannot be attracted to such proceedings. The position is also upheld by the Hon’ble High Court of Rajasthan