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    <title>2026 (4) TMI 473 - ITAT DELHI</title>
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    <description>Penalty under section 271DA for alleged contravention of section 269ST was not sustained because the assessee&#039;s explanation for the impugned cash receipt entries was found plausible on the facts. The Tribunal accepted that the income had been offered and tax paid to buy peace without admitting the Revenue&#039;s allegation of cash sales or receipt in the manner alleged. It also noted that penalty proceedings under section 270A had been dropped on a similar explanation, which supported the assessee&#039;s case. As the Revenue relied mainly on seized electronic material and surrounding search circumstances, the Tribunal held that the statutory precondition for penalty was not established to the required extent and deleted the levy.</description>
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      <title>2026 (4) TMI 473 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=789404</link>
      <description>Penalty under section 271DA for alleged contravention of section 269ST was not sustained because the assessee&#039;s explanation for the impugned cash receipt entries was found plausible on the facts. The Tribunal accepted that the income had been offered and tax paid to buy peace without admitting the Revenue&#039;s allegation of cash sales or receipt in the manner alleged. It also noted that penalty proceedings under section 270A had been dropped on a similar explanation, which supported the assessee&#039;s case. As the Revenue relied mainly on seized electronic material and surrounding search circumstances, the Tribunal held that the statutory precondition for penalty was not established to the required extent and deleted the levy.</description>
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      <pubDate>Wed, 25 Mar 2026 00:00:00 +0530</pubDate>
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