Penalty u/s 271D Invalid Due to Lack of Recorded Satisfaction for Section 269SS Violation. Penalty Cannot Be Levied.

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....Penalty u/s 271D - default of provisions of section 269SS - recording of satisfaction - since the assessment order as well as the order of the JCIT are devoid of any satisfaction regarding initiation of penalty proceedings u/s 271D - no penalty can be levied....