https://www.taxtmi.com/highlights?id=100612 Penalty proceedings under ss. 271D and 271E were held unsustainable where the Revenue relied only on entries in seized papers belonging to third parties, without proving that the assessee actually accepted or repaid cash loans. The Tribunal held that such proceedings are penal in nature and independent of assessment proceedings, so the initial burden remained on the Revenue. That burden was not discharged because the documents were not shown to be the assessee's own records, no evidence proved utilisation or repayment, and the assessee's request for copies and cross-examination was denied. The penalties were deleted. en-us Tue, 09 Jun 2026 07:50:17 +0530 Tue, 09 Jun 2026 07:50:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=100612 Penalty proceedings under ss. 271D and 271E were held unsustainable where the Revenue relied only on entries in seized papers belonging to third parties, without proving that the assessee actually accepted or repaid cash loans. The Tribunal held that such proceedings are penal in nature and independent of assessment proceedings, so the initial burden remained on the Revenue. That burden was not discharged because the documents were not shown to be the assessee's own records, no evidence proved utilisation or repayment, and the assessee's request for copies and cross-examination was denied. The penalties were deleted. Highlights Income Tax Tue, 09 Jun 2026 07:50:17 +0530 https://www.taxtmi.com/highlights?id=100612