Penalty under section 271D fails where the assessment order records no satisfaction for alleged section 269SS violation.

Penalty under section 271D was not leviable because the assessment order did not record satisfaction regarding any violation of section 269SS. The omission was treated as material, and the principle that penalty proceedings cannot be sustained without such satisfaction in the assessment order was applied. On that basis, the penalty was cancelled.

---

---

Issues: Whether penalty under section 271D of the Income-tax Act, 1961 could be sustained when the assessment order did not record any satisfaction regarding violation of section 269SS of the Income-tax Act, 1961.

Analysis: The assessment order contained an addition under section 50C of the Income-tax Act, 1961, but did not record satisfaction for initiation of penalty proceedings under section 271D. The absence of such satisfaction was held to be material, and the principle that penalty cannot be levied without satisfaction in the assessment order was applied.

Conclusion: Penalty under section 271D of the Income-tax Act, 1961 was not leviable and the penalty was cancelled.

---