https://www.taxtmi.com/caselaws?id=472150 Failure by an Assessing Officer to record satisfaction during assessment for initiating penalty proceedings for a Section 269SS contravention renders the assessment order erroneous and prejudicial to Revenue interests, permitting revision under Section 263. The Joint Commissioner's power to impose penalty under Section 271D does not remove the assessment-stage satisfaction requirement, and the Principal Commissioner has no corresponding power to levy that penalty. Cash received as unaccounted consideration on transfer of immovable property remains a "specified sum" under Section 269SS, even where it is separately assessed as income; income treatment creates no statutory exclusion. en-us Wed, 16 Apr 2025 00:00:00 +0530 Wed, 30 Sep 2026 19:00:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472150 Failure by an Assessing Officer to record satisfaction during assessment for initiating penalty proceedings for a Section 269SS contravention renders the assessment order erroneous and prejudicial to Revenue interests, permitting revision under Section 263. The Joint Commissioner's power to impose penalty under Section 271D does not remove the assessment-stage satisfaction requirement, and the Principal Commissioner has no corresponding power to levy that penalty. Cash received as unaccounted consideration on transfer of immovable property remains a "specified sum" under Section 269SS, even where it is separately assessed as income; income treatment creates no statutory exclusion. Case-Laws Income Tax Wed, 16 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472150