AO Cannot Refer File to JC Regarding Penalty u/s  271D of Income Tax without Recording “Satisfaction”: Andhra Pradesh HC 

The satisfaction of the Assessing Officer is required to be recorded because the officer, who passed the assessment order would not be levying the penalty under Sec.271D of the Act, unless it is recorded in the assessment order, he cannot refer the file to superior officer for initiating levy of penalty
Income Tax - Income Tax Act - Andhra Pradesh High Court - TAXSCAN

The Andhra Pradesh High Court in its recent ruling has held that an Assessing Officer ( AO ) cannot refer an assessee’s file to the Joint Commissioner of Income Tax for levying penalty under Section 271D of the Income Tax Act, 1961 without recording its “satisfaction”.The satisfaction of the Assessing Officer is required to be…

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