https://www.taxtmi.com/highlights?id=99951 Penalty under section 270A for alleged misreporting based on estimated gross profit additions could not be sustained where the Revenue relied on third-party electronic records seized in search without independent corroboration. The Tribunal held that the burden remained on the Revenue to substantiate the unmatched entries, and the assessee was not required to prove a negative. It also found that statements linked to the searched person could not be used conclusively against the assessee without corroborative material and cross-examination, and that the J-Pack ledger itself contained discrepancies. The penalties were deleted for all captioned assessment years, while the jurisdictional challenge to the section 153C assessment was left open. en-us Wed, 20 May 2026 08:31:08 +0530 Wed, 20 May 2026 08:31:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99951 Penalty under section 270A for alleged misreporting based on estimated gross profit additions could not be sustained where the Revenue relied on third-party electronic records seized in search without independent corroboration. The Tribunal held that the burden remained on the Revenue to substantiate the unmatched entries, and the assessee was not required to prove a negative. It also found that statements linked to the searched person could not be used conclusively against the assessee without corroborative material and cross-examination, and that the J-Pack ledger itself contained discrepancies. The penalties were deleted for all captioned assessment years, while the jurisdictional challenge to the section 153C assessment was left open. Highlights Income Tax Wed, 20 May 2026 08:31:08 +0530 https://www.taxtmi.com/highlights?id=99951