https://www.taxtmi.com/caselaws?id=468399 Penalty proceedings under Section 271D of the Income-tax Act must be founded on satisfaction recorded in the assessment proceedings. Where the assessment order contains no such recorded satisfaction or reference, the Joint Commissioner cannot validly initiate penalty independently from the assessment records alone. Sections 271D and 271E were treated as in pari materia, and the requirement of recorded satisfaction was applied in line with the governing principle recognised by the Supreme Court. On that basis, the penalty initiation was invalid and the penalty order, together with the appellate affirmation, was quashed. en-us Thu, 05 Mar 2026 00:00:00 +0530 Mon, 04 May 2026 19:59:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468399 Penalty proceedings under Section 271D of the Income-tax Act must be founded on satisfaction recorded in the assessment proceedings. Where the assessment order contains no such recorded satisfaction or reference, the Joint Commissioner cannot validly initiate penalty independently from the assessment records alone. Sections 271D and 271E were treated as in pari materia, and the requirement of recorded satisfaction was applied in line with the governing principle recognised by the Supreme Court. On that basis, the penalty initiation was invalid and the penalty order, together with the appellate affirmation, was quashed. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468399