On appeal by the revenue the Court held that the  penalty proceedings were initiated and then dropped which later order was revised under section 263. This was valid. Court also held that   no contention was taken regarding the prima facie satisfaction having not been recorded in the assessment order; which was never taken up earlier and which demonstrably was recorded in the assessment order. The penalty proceedings were valid. Satisfaction need not be recorded in particular form. (AY. 2004-05)