https://www.taxtmi.com/caselaws?id=31868 Where assessment orders were passed after 01.04.1989, the absence of an express recording of satisfaction for initiation of penalty under Section 271 did not by itself invalidate the proceedings because Section 271(1B), inserted by the Finance Act, 2008, applied through its retrospective deeming fiction. The Tribunal had confined its decision only to the recording-of-satisfaction issue and had not examined the merits of the penalty matters, so its orders could not stand on that limited basis alone. The Tribunal's orders were set aside and the matters were remitted for fresh on merits. en-us Thu, 04 Dec 2008 00:00:00 +0530 Wed, 24 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31868 Where assessment orders were passed after 01.04.1989, the absence of an express recording of satisfaction for initiation of penalty under Section 271 did not by itself invalidate the proceedings because Section 271(1B), inserted by the Finance Act, 2008, applied through its retrospective deeming fiction. The Tribunal had confined its decision only to the recording-of-satisfaction issue and had not examined the merits of the penalty matters, so its orders could not stand on that limited basis alone. The Tribunal's orders were set aside and the matters were remitted for fresh on merits. Case-Laws Income Tax Thu, 04 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31868