https://www.taxtmi.com/caselaws?id=779684 Where the original assessment order forming the basis for initiation of penalty proceedings under the IT Act was set aside, the "satisfaction" recorded in that assessment for initiating penalty under s. 271E was held to not survive, since the jurisdictional foundation for the penalty was extinguished with the annulment of the assessment order. The HC applied the SC's precedent that a penalty proceeding dependent on satisfaction recorded in an assessment cannot continue once that assessment is nullified. The SC found the issue squarely covered by its earlier decision and dismissed the SLP, leaving the HC's view intact and the penalty initiation invalidated. en-us Tue, 07 Oct 2025 00:00:00 +0530 Tue, 30 Dec 2025 16:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779684 Where the original assessment order forming the basis for initiation of penalty proceedings under the IT Act was set aside, the "satisfaction" recorded in that assessment for initiating penalty under s. 271E was held to not survive, since the jurisdictional foundation for the penalty was extinguished with the annulment of the assessment order. The HC applied the SC's precedent that a penalty proceeding dependent on satisfaction recorded in an assessment cannot continue once that assessment is nullified. The SC found the issue squarely covered by its earlier decision and dismissed the SLP, leaving the HC's view intact and the penalty initiation invalidated. Case-Laws Income Tax Tue, 07 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779684