2021 (9) TMI 1535

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..... sment order is conspicuously silent on recording of any satisfaction by the assessing officer for the purpose of initiative the penalty u/s 271D. In our considered opinion the recording of satisfaction by the AO is essential for initiation of any penalty u/s 271D of the act and failure to record, the satisfaction in the manner provided by the law and more particularly in the light of the judgem .....

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..... d.AR that in the assessment order the assessing officer has not mentioned about the satisfaction required to be mentioned for initiation of the penalty under section 271 D of the Income Tax Act he relied upon the decision of the Hon ble Apex Court in the matter of Jai Lakshmi Rice Mills. 64 taxmann.com 75 wherein the Hon ble Supreme Court in the identical facts and decided that in case the satisfa .....

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..... the parties and perused the material available on record, including the judgments cited at bar during the course of hearing by both the parties. We have perused the assessment order passed by the assessing officer the assessment order is conspicuously silent on recording of any satisfaction by the assessing officer for the purpose of initiative the penalty under section 271D of the Income Tax Act .....

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