Prior recorded satisfaction is required before penalty under section 271D can be validly initiated and levied.

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....Penalty under section 271D was held unsustainable where no assessment order existed in the assessee's case and, therefore, no prior recorded satisfaction could be discerned regarding the alleged section 269SS default. The Tribunal followed its earlier view in Umakant Sharma and held that initiation and levy of penalty without assessment proceedings in the assessee's case was legally invalid. The impugned penalty was directed to be deleted.....