Penalty initiation requires recorded satisfaction in the assessment order; separate notice could not sustain section 271D penalty.

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....Penalty under section 271D could not be sustained because no satisfaction was recorded in the assessment order initiating penalty proceedings. The Tribunal held that where the returned income was accepted and no quantum addition was made, there was no occasion in the assessment order to record the requisite satisfaction, and the Assessing Officer could not validly proceed by issuing a separate show-cause notice and penalty order. Relying on binding precedent, the Tribunal treated the absence of recorded satisfaction as fatal to jurisdiction and allowed the assessee's appeal without examining the merits.....