आदेश/ORDER

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 28.10.2025 of the learned CIT(A)-National Faceless Appeal Centre [in short “NFAC], Delhi, arising from the penalty Order passed u/sec.271D of the Income Tax Act [in short "the Act"], 1961 for the assessment year 2017-2018.

The assessee has raised the following grounds of appeal:

1. “The order of the learned Commissioner of Income Tax 1 (Appeals) is against the law, weight of evidence and probabilities of case.

2. The learned Commissioner ought to have appreciated that there is no satisfaction recorded by the AO in the assessment order for assessment year 2017-18, in respect of violation of provisions of section 269SS as envisaged in the case of Srinivas Reddy Reddeppagari Vs JCIT WP No.44285/2022, dt: 26.12.2022, by the Jurisdictional High Court of Telangana, therefore, erred in confirming the order of the JCIT levying penalty of Rs.36,00,000/- u/s 271D of the IT Act.

3. The learned Commissioner ought to have appreciated that it is a pre-requisite condition to levy penalty u/s 271D that there must be assessment proceedings in which the violation of 269SS is noticed, in the