https://www.taxtmi.com/caselaws?id=798199 Before 1 April 2025, penalty jurisdiction for contraventions of Section 269SS under Section 271D lay with the Joint/Additional Commissioner, not the Assessing Officer. Section 271D neither requires recording of penalty satisfaction in the assessment order nor makes such satisfaction part of assessment proceedings, because penalty proceedings are independent. Accordingly, an Assessing Officer's failure to record satisfaction for Section 271D penalty could not render an assessment order erroneous and prejudicial to Revenue interests. Revisionary action under Section 263 on that basis was without jurisdiction, resulting in quashing of the revision orders and reinstatement of the assessments. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798199 Before 1 April 2025, penalty jurisdiction for contraventions of Section 269SS under Section 271D lay with the Joint/Additional Commissioner, not the Assessing Officer. Section 271D neither requires recording of penalty satisfaction in the assessment order nor makes such satisfaction part of assessment proceedings, because penalty proceedings are independent. Accordingly, an Assessing Officer's failure to record satisfaction for Section 271D penalty could not render an assessment order erroneous and prejudicial to Revenue interests. Revisionary action under Section 263 on that basis was without jurisdiction, resulting in quashing of the revision orders and reinstatement of the assessments. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798199