https://www.taxtmi.com/caselaws?id=781604 ITAT, Delhi held that satisfaction required to initiate penalty under s.271DA for breach of s.269ST must be recorded in the assessment order itself while examining transactions; absent such recorded satisfaction the penalty proceeding is time-barred. The bench applied the SC principle that fresh assessment must also record satisfaction before imposing penalty, reasoning that penalties under ss.271D and 271DA are pari materia aimed at curbing cash circulation. Order resolved in favour of the taxpayer. en-us Fri, 14 Nov 2025 00:00:00 +0530 Sat, 15 Nov 2025 13:48:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781604 ITAT, Delhi held that satisfaction required to initiate penalty under s.271DA for breach of s.269ST must be recorded in the assessment order itself while examining transactions; absent such recorded satisfaction the penalty proceeding is time-barred. The bench applied the SC principle that fresh assessment must also record satisfaction before imposing penalty, reasoning that penalties under ss.271D and 271DA are pari materia aimed at curbing cash circulation. Order resolved in favour of the taxpayer. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781604