Held that  satisfaction note was recorded by TPO to initiate penalty proceedings under section 271(1)(c) for non-compliance of notice issued to assessee to furnish necessary documents for completion of transfer pricing proceedings under section 92CA instead of section 92D of the  Act.  Tribunal held that  notice was required to be issued under section 92D to attract provisions contained under section 271G, and consequently, when valid satisfaction had not been recorded, no penalty under section 271G could be levied. (AY. 2013-14)