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    <title>2026 (2) TMI 379 - SC Order</title>
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    <description>Penalty under section 271D for violation of section 269SS requires the Assessing Officer to record satisfaction during assessment proceedings before the Joint Commissioner can exercise penalty jurisdiction. The text notes that, where the same officer who completes the assessment is not the authority imposing penalty, the precondition of recorded satisfaction is treated as necessary for valid levy. It also records that the Special Leave Petition was filed with a gross delay of 350 days, the delay was not satisfactorily explained, and no reason was found to interfere with the High Court order; the petition was dismissed on delay and on merits.</description>
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      <description>Penalty under section 271D for violation of section 269SS requires the Assessing Officer to record satisfaction during assessment proceedings before the Joint Commissioner can exercise penalty jurisdiction. The text notes that, where the same officer who completes the assessment is not the authority imposing penalty, the precondition of recorded satisfaction is treated as necessary for valid levy. It also records that the Special Leave Petition was filed with a gross delay of 350 days, the delay was not satisfactorily explained, and no reason was found to interfere with the High Court order; the petition was dismissed on delay and on merits.</description>
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