penalty under Section 271D
of the Act should not be levied for violation of the provisions of Section
269SS of the Act. The appellant submitted ... power under
Section 271D(2) of the Act initiate the proceedings on its own on the
ground of violation of Section 269SS
violation of section 269SS . Since the
penalty u/s 271D for violation of section 269SS could be imposed by
Addl. Commissioner, the AO referred matter ... reckoning the limitation prescribed in section 275(1)(c) ? While the
assessee claims that the contravention of section 269SS was found by
AO in assessment
consequential amendments in
section 271D and section 271E to provide penalty for failure to
comply with the amended provisions of section 269SS and 269T ,
respectively ... Consequential amendments in section 271D
and section 271E , to provide penalty for failure to comply
with the amended provisions of section 269SS and 269T ,
respectively
erred in upholding penalty under Section 271D for
violation of provisions of Section 269SS of the Act, and claimed
15
ITA Nos.1255 to 1257 ... taking necessary action for imposition of penalty u/s 271D for
violation of section 269SS of the Act, on 30.03.2023. Therefore, as
per the provisions
consequential amendments in
section 271D and section 271E to provide penalty for failure to
comply with the amended provisions of section 269SS and 269T ,
respectively ... Consequential amendments in section 271D and
section 271E , to provide penalty for failure to comply with the
amended provisions of section 269SS and 269T , respectively
initiating proceedings
u/s 263 of the Act, vide Notice dated 13.02.2025 has raised two issues (i)
violation of provisions of section 269SS liable ... levy of penalty u/s 271D of
the Act (ii) violation of the provisions of section 269T liable for levy of penalty
u/s 271E
under section 271D of the Act for the alleged
violation of section 269SS of the Act, and the order of Id.
CIT(A)/NFAC sustaining ... initiation of the penalty proceedings u/ sec.271D of the Act
for violation of the provisions of sec.269SS of the Act.
Thereafter, the JCIT
consequential amendments in
section 271D and section 271E to provide penalty for failure
to comply with the amended provisions of section 269SS and
269T , respectively ... Consequential amendments in section 271D
and section 271E , to provide penalty for failure to comply
with the amended provisions of section 269SS and 269T ,
respectively
consequential amendments in
section 271D and section 271E to provide penalty for failure
to comply with the amended provisions of section 269SS and
269T , respectively ... Consequential amendments in section 271D
and section 271E , to provide penalty for failure to comply
with the amended provisions of section 269SS and 269T ,
respectively
penalty imposable under sub- section (1) shall be
imposed by the [Joint] Commissioner.]
19. Thus, what sub-section (1) of Section 271D provides ... penalty imposable under sub-section (1) shall be
imposed by the [Joint] Commissioner.]
21. Thus, sub-section (1) of Section 271E of the Act provides
