https://www.taxtmi.com/caselaws?id=798838 Penalty proceedings for an alleged contravention of Section 269SS require foundational satisfaction recorded and discernible during assessment proceedings. Although the authority imposing penalty under Section 271D may differ from the assessing authority, a later show-cause notice cannot replace absent satisfaction in the assessment order. Participation in penalty proceedings does not cure that jurisdictional defect. Where the assessment order neither identifies a contravention of Section 269SS nor indicates initiation of Section 271D proceedings, the penalty proceedings are invalid and the penalty cannot be sustained. en-us Wed, 09 Sep 2026 00:00:00 +0530 Sat, 12 Sep 2026 08:41:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798838 Penalty proceedings for an alleged contravention of Section 269SS require foundational satisfaction recorded and discernible during assessment proceedings. Although the authority imposing penalty under Section 271D may differ from the assessing authority, a later show-cause notice cannot replace absent satisfaction in the assessment order. Participation in penalty proceedings does not cure that jurisdictional defect. Where the assessment order neither identifies a contravention of Section 269SS nor indicates initiation of Section 271D proceedings, the penalty proceedings are invalid and the penalty cannot be sustained. Case-Laws Income Tax Wed, 09 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798838