Absence of recorded satisfaction in the assessment order for...

Absence of recorded satisfaction in the assessment order for initiating penalty proceedings rendered penalty under section 271E unsustainable, where the assessment under section 143(3) accepted the returned income and contained no finding of violation of section 269T. Applying CIT v. Jai Laxmi Rice Mills, the Tribunal held that penalty proceedings cannot survive without such satisfaction in the assessment order and directed deletion of the penalty.