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Default committed prior to amendment date when power to impose penalty was introduced couldn't be punished

October 5, 2018[2018] 98 395 (Delhi)/[2019] 411 ITR 333 (Delhi)

IT/ILT : Where assessee failed to produce requisite documents under section 92D(3) in response to notice issued by TPO, in view of fact that said event of default occurred in March, 2014 i.e. prior to amendment dated 1-10-2014, when power to impose penalty under section 271G was with AO, impugned penalty order passed by TPO being without Jurisdiction, deserved to be set aside

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