https://www.taxtmi.com/caselaws?id=792668 Penalty proceedings under Sections 271D and 271E require the Assessing Officer to record satisfaction in the reassessment order itself; without that recorded satisfaction, the penalty cannot be sustained. The Rajasthan HC applied this principle, relying on Jai Laxmi Rice Mills, in matters concerning Assessment Year 2012-13. The Supreme Court later declined to condone delay in the special leave petitions, which were filed beyond time by 369 and 356 days, and dismissed them on limitation grounds. en-us Fri, 29 May 2026 00:00:00 +0530 Mon, 01 Jun 2026 08:25:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792668 Penalty proceedings under Sections 271D and 271E require the Assessing Officer to record satisfaction in the reassessment order itself; without that recorded satisfaction, the penalty cannot be sustained. The Rajasthan HC applied this principle, relying on Jai Laxmi Rice Mills, in matters concerning Assessment Year 2012-13. The Supreme Court later declined to condone delay in the special leave petitions, which were filed beyond time by 369 and 356 days, and dismissed them on limitation grounds. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792668