Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 271D.

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....Penalty for cash receipt of immovable-property sale consideration requires foundational satisfaction during assessment proceedings that section 269SS was contravened and that penalty proceedings should be initiated. The Joint Commissioner's separate authority to impose penalty cannot cure the absence of this recorded satisfaction through a later show-cause notice. Where the assessment order contains no finding of contravention or indication of proposed penalty proceedings, subsequent initiation lacks jurisdiction; participation by the assessee does not validate it. The penalty under section 271D was consequently quashed, while the alternative reasonable-cause plea remained open.....