Penalty u/s 271D - violation of provisions u/s 269SS - cash...

Penalty u/s 271D - violation of provisions u/s 269SS - cash receipt claimed as advance against sales - recording of the satisfaction by the AO is sine qua non for initiating the penalty u/s 271D - AO though had mentioned that the AO has proposed the imposition of penalty u/s 271D for violation of the provisions of section 269SS, however, after looking into the assessment order reproduced herein below, it is abundantly clear that neither such proposal for imposition of penalty u/s 271D was proposed by the Assessing Officer nor any satisfaction for initiation of penalty was recorded in the assessment order. - AT