https://www.taxtmi.com/caselaws?id=760001 HC set aside levy of penalty under section 271D, holding that the Assessing Officer did not record any satisfaction that section 269SS was violated and thus effectively accepted the assessee's explanation denying cash loan. Absent recorded satisfaction by the AO, the Joint Commissioner lacked jurisdiction to initiate penalty proceedings under section 271D. The court relied on controlling SC precedent and concluded there was no occasion to sustain the penalty where the primary authority did not find a breach of section 269SS. en-us Thu, 03 Oct 2024 00:00:00 +0530 Sat, 15 Nov 2025 13:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760001 HC set aside levy of penalty under section 271D, holding that the Assessing Officer did not record any satisfaction that section 269SS was violated and thus effectively accepted the assessee's explanation denying cash loan. Absent recorded satisfaction by the AO, the Joint Commissioner lacked jurisdiction to initiate penalty proceedings under section 271D. The court relied on controlling SC precedent and concluded there was no occasion to sustain the penalty where the primary authority did not find a breach of section 269SS. Case-Laws Income Tax Thu, 03 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760001