https://www.taxtmi.com/caselaws?id=468787 Penalty proceedings are independent of assessment proceedings, so the assessee could contest the penalty basis even without appealing the assessment orders. The levy under section 270A failed because the additions were based on ledger extracts and sworn statements that did not conclusively establish that the "SABARI" entry belonged to the assessee or that unaccounted purchases were made. Material discrepancies in the seized extracts and the denial of an effective opportunity to cross-examine further undermined the penalty case. Penalty cannot be sustained on loose sheets or uncorroborated material alone, and the penalty was deleted for all years in appeal. en-us Fri, 24 Oct 2025 00:00:00 +0530 Tue, 19 May 2026 16:49:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468787 Penalty proceedings are independent of assessment proceedings, so the assessee could contest the penalty basis even without appealing the assessment orders. The levy under section 270A failed because the additions were based on ledger extracts and sworn statements that did not conclusively establish that the "SABARI" entry belonged to the assessee or that unaccounted purchases were made. Material discrepancies in the seized extracts and the denial of an effective opportunity to cross-examine further undermined the penalty case. Penalty cannot be sustained on loose sheets or uncorroborated material alone, and the penalty was deleted for all years in appeal. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468787