https://www.taxtmi.com/caselaws?id=791932 Penalty under section 270A(9)(e) of the Income-tax Act could not be sustained where it rested only on entries in a third party's software ledger and statements of persons linked to that third party. The assessee's books, invoices, bank records and reconciliation, together with demonstrated discrepancies in the disputed ledger, undermined the Revenue's case. Material seized from the searched person carried a statutory presumption only against that person and was not conclusive against the assessee. In the absence of independent corroboration and effective cross-examination of the relied-upon witnesses, the third-party entries were unsafe to found penal liability on, and the penalty was deleted. en-us Tue, 05 May 2026 00:00:00 +0530 Tue, 19 May 2026 16:07:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791932 Penalty under section 270A(9)(e) of the Income-tax Act could not be sustained where it rested only on entries in a third party's software ledger and statements of persons linked to that third party. The assessee's books, invoices, bank records and reconciliation, together with demonstrated discrepancies in the disputed ledger, undermined the Revenue's case. Material seized from the searched person carried a statutory presumption only against that person and was not conclusive against the assessee. In the absence of independent corroboration and effective cross-examination of the relied-upon witnesses, the third-party entries were unsafe to found penal liability on, and the penalty was deleted. Case-Laws Income Tax Tue, 05 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791932