PCIT v. Parivar Television Pvt. Ltd. (2025) 481 ITR 14 /(2026) 308 Taxman 186 (SC) Editorial : PCIT v. Parivar Television Pvt. Ltd (2025) 483 ITR 391/180 taxmann.co 109 (Guj)(HC)

S.271D: Penalty-Takes or accepts any loan or deposit-Assessing Officer not recording satisfaction in assessment order that there had been violation of section 269SS-High Court quashed the penalty order-SLP dismissed.[S. 269SS, Art. 136]

 

High Court following the ration in CIT v. Jai Laxmi Rice Mills, (2015) 379 ITR 521 (SC),  dismissed the Department’s appeal holding that, there being no mention in the assessment order regarding initiation of penalty proceedings under section 271D of the Income-tax Act, 1961, no satisfaction having been recorded by the Assessing Officer before initiating penalty proceedings, no penalty under section 271D could be levied. SLP dismissed.[BP. 1-4 1995 to 19-12-2001]

 

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