https://www.taxtmi.com/caselaws?id=791119 Penalty under section 271D was found unsustainable because the assessment order did not record satisfaction for the alleged contravention of section 269SS, and such recorded satisfaction in the assessment proceedings was treated as a mandatory condition for valid initiation. The Tribunal admitted the additional ground as a pure question of law because it went to the root of the matter and required no fresh factual inquiry. Relying on binding jurisdictional and Supreme Court authority, it also treated sections 271D and 271E as pari materia and followed the view that absence of recorded satisfaction in the original assessment order was fatal to the penalty proceedings. en-us Thu, 30 Apr 2026 00:00:00 +0530 Mon, 04 May 2026 11:27:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791119 Penalty under section 271D was found unsustainable because the assessment order did not record satisfaction for the alleged contravention of section 269SS, and such recorded satisfaction in the assessment proceedings was treated as a mandatory condition for valid initiation. The Tribunal admitted the additional ground as a pure question of law because it went to the root of the matter and required no fresh factual inquiry. Relying on binding jurisdictional and Supreme Court authority, it also treated sections 271D and 271E as pari materia and followed the view that absence of recorded satisfaction in the original assessment order was fatal to the penalty proceedings. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791119