Penalty under section 271DA required a clear jurisdictional...

Penalty under section 271DA required a clear jurisdictional foundation in the assessment order itself, including recorded satisfaction identifying the alleged cash receipt and the ingredients of section 269ST; a bare reference to penalty proceedings was insufficient, so jurisdiction failed and the penalty order was quashed. On merits, contravention had to be proved by cogent corroborative material showing person-wise, transaction-wise or event-wise receipt beyond the statutory threshold; uncorroborated tally data, statements and estimated income from rejected books did not discharge the Revenue's burden, so the penalty was deleted.

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