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Penalty under section 271D cannot survive once the reassessment orders and the recorded satisfaction forming its basis are quashed, because the alleged section 269SS violation loses its substratum. The Tribunal also held that levy of penalty requires reliable independent evidence of actual acceptance of cash loans or deposits; third-party statements and alleged coded entries, without corroboration in the assessee's books or other incriminating material, were insufficient. As the related additions had already been deleted and no separate proof of cash borrowing was established, the penalties for both assessment years were held unsustainable and directed to be deleted.
Penalty under section 271D cannot survive once the reassessment orders and the recorded satisfaction forming its basis are quashed, because the alleged section 269SS violation loses its substratum. The Tribunal also held that levy of penalty requires reliable independent evidence of actual acceptance of cash loans or deposits; third-party statements and alleged coded entries, without corroboration in the assessee's books or other incriminating material, were insufficient. As the related additions had already been deleted and no separate proof of cash borrowing was established, the penalties for both assessment years were held unsustainable and directed to be deleted.
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