https://www.taxtmi.com/caselaws?id=795007 Recording of satisfaction by the Assessing Officer during assessment proceedings for a Section 269SS violation is a jurisdictional prerequisite for penalty proceedings under Section 271D. Satisfaction recorded only for proceedings concerning Section 269ST, which were later dropped, does not authorise the Joint Commissioner to independently initiate Section 271D proceedings. Such proceedings are without jurisdiction and the penalty is liable to be deleted. The limitation period under Section 275(1)(c), calculated from the relevant assessment-order satisfaction, cannot be extended or revived by dropping the earlier proceedings and initiating fresh proceedings under Section 271D; proceedings commenced after expiry are time-barred. en-us Fri, 10 Jul 2026 00:00:00 +0530 Wed, 15 Jul 2026 08:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795007 Recording of satisfaction by the Assessing Officer during assessment proceedings for a Section 269SS violation is a jurisdictional prerequisite for penalty proceedings under Section 271D. Satisfaction recorded only for proceedings concerning Section 269ST, which were later dropped, does not authorise the Joint Commissioner to independently initiate Section 271D proceedings. Such proceedings are without jurisdiction and the penalty is liable to be deleted. The limitation period under Section 275(1)(c), calculated from the relevant assessment-order satisfaction, cannot be extended or revived by dropping the earlier proceedings and initiating fresh proceedings under Section 271D; proceedings commenced after expiry are time-barred. Case-Laws Income Tax Fri, 10 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795007