https://www.taxtmi.com/caselaws?id=792288 Penalty under section 271DA could not be sustained where the Revenue relied solely on electronic material from search without establishing a complete chain of custody and admissibility of the digital evidence. The Tribunal held that authenticity, integrity, and evidentiary safeguards for electronic records must be shown before such material can fasten liability, and the assessee succeeded on that issue. It also held that a cash receipt characterised as a loan transaction did not attract section 269ST because the statutory exception tied to transactions governed by section 269SS applied. On that basis, the penalty had no valid statutory foundation and was set aside. en-us Fri, 22 May 2026 00:00:00 +0530 Tue, 26 May 2026 08:24:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792288 Penalty under section 271DA could not be sustained where the Revenue relied solely on electronic material from search without establishing a complete chain of custody and admissibility of the digital evidence. The Tribunal held that authenticity, integrity, and evidentiary safeguards for electronic records must be shown before such material can fasten liability, and the assessee succeeded on that issue. It also held that a cash receipt characterised as a loan transaction did not attract section 269ST because the statutory exception tied to transactions governed by section 269SS applied. On that basis, the penalty had no valid statutory foundation and was set aside. Case-Laws Income Tax Fri, 22 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792288