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HC ruled penalty proceedings under sections 271D and 271E require explicit satisfaction to be recorded by Assessing Officer during reassessment. Mere recording of satisfaction for section 271(1)(c) proceedings is insufficient. Following Jai Laxmi Rice Mills precedent, where penalty was quashed due to lack of specific satisfaction, the court held that DCIT's recording of satisfaction only for 271(1)(c) without addressing 271D/E requirements was legally deficient. Consequently, the notice issued under section 271E and subsequent proceedings were quashed, with judgment favoring the assessee due to procedural non-compliance in recording mandatory satisfaction.
HC ruled penalty proceedings under sections 271D and 271E require explicit satisfaction to be recorded by Assessing Officer during reassessment. Mere recording of satisfaction for section 271(1)(c) proceedings is insufficient. Following Jai Laxmi Rice Mills precedent, where penalty was quashed due to lack of specific satisfaction, the court held that DCIT's recording of satisfaction only for 271(1)(c) without addressing 271D/E requirements was legally deficient. Consequently, the notice issued under section 271E and subsequent proceedings were quashed, with judgment favoring the assessee due to procedural non-compliance in recording mandatory satisfaction.
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