Recorded satisfaction is mandatory before penalty for cash loan acceptance; absence of it renders the penalty unsustainable.

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....Penalty for acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.....