[2025:RJ-JP:14988-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 3537/2025 Pawan Kumar Jain S/o Shri Nathu Lal Jain, Aged About 49 Years, C/o Chanda Lal Kalyan Mal And Sons, 1, Near Jaipur Glass Factory, Tonk Road, Jaipur-302015 ----Petitioner Versus 1. Additional/joint Commissioner Of Income Tax Central, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur-302005 2. Deputy Commissioner Of Income Tax, Central Cirlce-1, 4Th Floor, Jeevan Nidhi-2, Lic Building, Ambedkar Circle, Jaipur-302005 3. Principal Commissioner Of Income Tax (Central), New Central Revenue Building, Bhagwan Das Road, Jaipur, Rajasthan 302005 ----Respondents For Petitioner(s) : Mr. Tanuj Agrawal For Respondent(s) : Mr. Siddharth Bapna with Mr. Meyhul Mittal HON'BLE THE CHIEF JUSTICE MR. MANINDRA MOHAN SHRIVASTAVA HON'BLE MR. JUSTICE ANAND SHARMA Order 03/04/2025 1. Learned counsel for the petitioner submits that the issue raised in this petition is squarely covered by order dated 30.01.2025 passed by a Division Bench of this Court in D.B. Civil Writ Petition No. 1102/2025-Sunil Agrawal Vs. Assistant Commissioner of Income Tax and batch of petitions wherein it has been held that where no satisfaction is recorded, as required under Section 271E of the Act and even though AO has directed [2025:RJ-JP:14988-DB] (2 of 2) [CW-3537/2025] initiation of proceedings under Section 271(1)(c) of the Act, the penalty proceedings are liable to be quashed in the absence of satisfaction. He would submit that on facts also, in the assessment order dated 22.02.2024, no such satisfaction as required under the law for initiation of proceedings under Section 271D of the Act of 1961 has been recorded. Therefore, the penalty proceedings are liable to be quashed. 2. Learned counsel for the respondents is not in a position to dispute the factual statement and the legal position, as stated hereinabove. 3. In that view of the matter, the penalty proceedings initiated in this case are also liable to be quashed and, accordingly, the same is quashed. 4. The petition is, accordingly, allowed. (ANAND SHARMA),J (MANINDRA MOHAN SHRIVASTAVA),CJ N.Gandhi/Neeru/15