https://www.taxtmi.com/caselaws?id=792354 Penalty under section 271D based on alleged cash loans does not survive where the reassessment proceedings and the foundational satisfaction for initiation of penalty have been quashed, unless the Revenue independently proves the cash transaction constituting the contravention. The text also states that penalty proceedings are conceptually independent for limitation purposes, but that independence does not preserve a penalty when its underlying basis has been invalidated. In the absence of independent incriminating material beyond third-party statements and coded seized entries, the alleged violation of section 269SS was not established on sustainable evidence, and the penalties were deleted. en-us Fri, 22 May 2026 00:00:00 +0530 Wed, 27 May 2026 07:29:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792354 Penalty under section 271D based on alleged cash loans does not survive where the reassessment proceedings and the foundational satisfaction for initiation of penalty have been quashed, unless the Revenue independently proves the cash transaction constituting the contravention. The text also states that penalty proceedings are conceptually independent for limitation purposes, but that independence does not preserve a penalty when its underlying basis has been invalidated. In the absence of independent incriminating material beyond third-party statements and coded seized entries, the alleged violation of section 269SS was not established on sustainable evidence, and the penalties were deleted. Case-Laws Income Tax Fri, 22 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792354