https://www.taxtmi.com/caselaws?id=793115 Penalty under sections 271D and 271E for alleged cash loans and repayments was deleted because the Revenue relied only on uncorroborated third-party seized material. The underlying quantum addition had already been removed for failure to prove the existence, use, or repayment of the alleged loans, and penalty could not survive without independent proof of contravention of sections 269SS and 269T. No incriminating material was found from the assessee's premises, and the denial of document supply and cross-examination left the third-party material unreliable. The Revenue therefore failed to discharge the burden of proving actual acceptance and repayment of cash loans, and penal liability was not established. en-us Thu, 04 Jun 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793115 Penalty under sections 271D and 271E for alleged cash loans and repayments was deleted because the Revenue relied only on uncorroborated third-party seized material. The underlying quantum addition had already been removed for failure to prove the existence, use, or repayment of the alleged loans, and penalty could not survive without independent proof of contravention of sections 269SS and 269T. No incriminating material was found from the assessee's premises, and the denial of document supply and cross-examination left the third-party material unreliable. The Revenue therefore failed to discharge the burden of proving actual acceptance and repayment of cash loans, and penal liability was not established. Case-Laws Income Tax Thu, 04 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793115