The AO neither recorded a finding nor expressed satisfaction that the assessee had violated section 269SS by accepting a loan in cash; the Joint Commissioner lacked jurisdiction to initiate and levy a penalty under section 271D. In the absence of such satisfaction in the assessment proceedings, penalty proceedings were unsustainable. Further, the Revenue failed to satisfactorily explain the delay of 350 days in filing the SLP, and no error was found in the High Court’s decision. SLP of the revenue dismissed on account of delay and also on merits  (AY. 2017-18)