In the result, appeal filed by the assessee is allowed
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
condonation of delay is thus unjustified and unwarranted. 4. Order imposing penalty u/s 271D of I.T. Act 1961 is illegal, invalid and bad in law in the absence of any satisfaction in the assessment proceedings in the case of assessee. 5. In levy of penalty u/s 271D on amount of Rs.6,51,000/- includes Rs.6,00,000/- paid by cheque