Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Penalty under Section 271DA was quashed because it rested on seized digital material and an alleged hawala token that had already been found inadmissible in the connected group case; once that electronic material could not validly support factual findings, it could not sustain the penalty. The Tribunal also held that the underlying transaction was a loan transaction and, if at all, fell within Section 269SS rather than Section 269ST. Since Section 269ST excludes transactions covered by Section 269SS, the penalty premised on Section 269ST was not legally tenable.
Penalty under Section 271DA was quashed because it rested on seized digital material and an alleged hawala token that had already been found inadmissible in the connected group case; once that electronic material could not validly support factual findings, it could not sustain the penalty. The Tribunal also held that the underlying transaction was a loan transaction and, if at all, fell within Section 269SS rather than Section 269ST. Since Section 269ST excludes transactions covered by Section 269SS, the penalty premised on Section 269ST was not legally tenable.
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