AdvertisementDCIT Vs Harish Kumar Agrawal (ITAT Delhi) Delhi ITAT: Section 271D Penalty Cannot Survive After Quantum Assessment is Quashed; Limitation Runs from AO’s Satisfaction The Delhi ITAT dismissed the Revenue’s appeal and upheld the deletion of penalty under section 271D, holding that once the underlying assessment giving rise to the penalty is quashed, the very foundation for the penalty disappears. The Tribunal also reaffirmed that the limitation period under section 275(1)(c) is to be computed from the date on which the Assessing Officer records satisfaction for initiating penalty p...