Assessee received loan of Rs. 6.65 crores and repaid a sum of Rs. 7.70 crores. Assessing Officer held that assessee had accepted loans in cash. He further held that assessee paid an amount of Rs. 1.05 crores in excess. Assessing Officer taking note of letter of assessee, acknowledging receipt of amount of Rs. 6.65 crores made addition under section 69A on account of such excess amount which according to Assessing Officer was excess payment over and above loans accepted as unexplained money. Commissioner had initiated penalty proceedings under section 271D and levied penalty of certain amount.  Assessing Officer, except to base his addition on letter of assessee, did not record any finding that there had been any violation of provisions of section 269SS by assessee, nor was any satisfaction recorded to effect that alleged transaction of acceptance of loan would attract penal consequences. On writ  the Court held that since the  Assessing Officer did not record any satisfaction in assessment order to effect that provisions of section 269SS were violated and did not contemplate levy of penalty under section 271D. Penalty levied is set aside.