On writ against the penalty order, the Court held that no penalty could be levied without recorded satisfaction. Accordingly the order is set aside and the matter is remanded back to the file of the Assessing Officer to pass a fresh order in accordance with law after giving a reasonable opportunity of hearing. Followed CIT v. Jai Laxmi Rice Mills (2016)286 CTR 159 / 134 DTR 223 (SC) (AY. 2016-17)
Srinivasa Reddy Reddeppagari v. JCIT (2023) 332 CTR 614(Telangana) (HC)
S. 271D : Penalty-Takes or accepts any loan or deposit-No satisfaction is recorded-Matter is remanded back to the file of Assessing Officer to pass fresh order in accordance with law. [S. 269SS, Art. 226]