https://www.taxtmi.com/caselaws?id=789269 Penalty under section 271D could not be sustained where the alleged cash loan transaction itself remained unproved. The record referred to seized material and a third-party statement, but the assessee consistently denied having taken the loan and the quantum assessment had already been quashed on legal grounds without any final finding establishing the transaction. Uncertainty also remained about the alleged intermediary and the directness of the loan arrangement, and no effective enquiry was made to verify it. On these facts, the alleged breach of section 269SS was not established and the penalty failed. en-us Wed, 25 Mar 2026 00:00:00 +0530 Mon, 06 Apr 2026 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789269 Penalty under section 271D could not be sustained where the alleged cash loan transaction itself remained unproved. The record referred to seized material and a third-party statement, but the assessee consistently denied having taken the loan and the quantum assessment had already been quashed on legal grounds without any final finding establishing the transaction. Uncertainty also remained about the alleged intermediary and the directness of the loan arrangement, and no effective enquiry was made to verify it. On these facts, the alleged breach of section 269SS was not established and the penalty failed. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789269