u/s 271D of the Act without any assessment\nproceedings in the case of the assessee is not valid and liable to be\nquashed. We order accordingly.\n7.\nThus, it is a pre-requisite condition for initiation of the\npenalty u/sec.271D/271E of the Act that there must be an assessment\nproceeding or proceedings arising from assessment order or any other\nproceedings