https://www.taxtmi.com/caselaws?id=796881 Penalty under Section 271D for contravention of Section 269SS cannot subsist where the assessment order containing the Assessing Officer's recorded satisfaction to initiate penalty proceedings has been quashed. The corresponding principle applicable to Section 271E applies because Sections 271D and 271E are pari materia. Independently, where satisfaction and penalty initiation occur in the assessment order, the limitation period under Section 275(1)(c) runs from that initiation, not from a later notice or action by the competent penalty authority. The penalty was therefore unsustainable on both its invalid foundation and limitation. en-us Wed, 05 Aug 2026 00:00:00 +0530 Wed, 12 Aug 2026 08:20:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796881 Penalty under Section 271D for contravention of Section 269SS cannot subsist where the assessment order containing the Assessing Officer's recorded satisfaction to initiate penalty proceedings has been quashed. The corresponding principle applicable to Section 271E applies because Sections 271D and 271E are pari materia. Independently, where satisfaction and penalty initiation occur in the assessment order, the limitation period under Section 275(1)(c) runs from that initiation, not from a later notice or action by the competent penalty authority. The penalty was therefore unsustainable on both its invalid foundation and limitation. Case-Laws Income Tax Wed, 05 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796881