https://www.taxtmi.com/caselaws?id=785233 The note addresses initiation of penalty under the Act for repayments not made by prescribed modes, holding that initiation requires the assessing officer's recorded satisfaction in the assessment order; absence of such satisfaction precludes initiation of penalty proceedings and the Commissioner cannot direct initiation on revision under section 263 in those circumstances. The impugned direction to initiate penalty without AO satisfaction was set aside and the assessee's appeal allowed, reaffirming the separation between assessment satisfaction and subsequent penalty initiation and limiting revisionary power to direct such initiation. 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 The note addresses initiation of penalty under the Act for repayments not made by prescribed modes, holding that initiation requires the assessing officer's recorded satisfaction in the assessment order; absence of such satisfaction precludes initiation of penalty proceedings and the Commissioner cannot direct initiation on revision under section 263 in those circumstances. The impugned direction to initiate penalty without AO satisfaction was set aside and the assessee's appeal allowed, reaffirming the separation between assessment satisfaction and subsequent penalty initiation and limiting revisionary power to direct such initiation. Case-Laws Income Tax Fri, 16 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785233