Recording satisfaction in assessment proceedings is essential before cash-receipt penalties can be initiated; absent satisfaction, penalty fails.

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....Recording satisfaction during assessment proceedings is required before penalty for an alleged cash-receipt contravention of section 269SS can be validly initiated. Applying the Supreme Court principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of any satisfaction or penalty initiation in the assessment order as an invalid assumption of jurisdiction. It deleted the penalty under section 271D without deciding whether section 269SS applied to cash sale consideration for immovable property.....