https://www.taxtmi.com/caselaws?id=785233 Revisionary powers cannot direct initiation of penalty proceedings under section 271E where the Assessing Officer did not record the requisite satisfaction in the assessment order. Although the tax audit report recorded repayment otherwise than through permitted banking modes, and assertions that it was a security-deposit adjustment or book entry were not supported by a revised audit report or auditor's certificate, that reporting alone did not cure the absence of recorded satisfaction. The direction under section 263 to initiate penalty for alleged contravention of section 269T was therefore unsustainable, and the revisionary order was set aside. en-us Fri, 16 Jan 2026 00:00:00 +0530 Tue, 20 Jan 2026 06:31:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785233 Revisionary powers cannot direct initiation of penalty proceedings under section 271E where the Assessing Officer did not record the requisite satisfaction in the assessment order. Although the tax audit report recorded repayment otherwise than through permitted banking modes, and assertions that it was a security-deposit adjustment or book entry were not supported by a revised audit report or auditor's certificate, that reporting alone did not cure the absence of recorded satisfaction. The direction under section 263 to initiate penalty for alleged contravention of section 269T was therefore unsustainable, and the revisionary order was set aside. Case-Laws Income Tax Fri, 16 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785233