https://www.taxtmi.com/caselaws?id=793953 Penalty under section 271DA requires a clear recorded satisfaction in the assessment order that the ingredients of section 269ST are met; without such jurisdictional satisfaction, initiation of penalty proceedings is invalid. The penalty also cannot be sustained on estimated income, seized tally data or statements alone unless the Revenue proves, with independent and transaction-wise evidence, that an identifiable person made prohibited cash receipts breaching section 269ST. Rejected books, estimated assessments and uncorroborated admissions of additional income do not by themselves establish the statutory violation. On these principles, the penalty was held unsustainable in law. en-us Wed, 24 Jun 2026 00:00:00 +0530 Fri, 26 Jun 2026 07:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793953 Penalty under section 271DA requires a clear recorded satisfaction in the assessment order that the ingredients of section 269ST are met; without such jurisdictional satisfaction, initiation of penalty proceedings is invalid. The penalty also cannot be sustained on estimated income, seized tally data or statements alone unless the Revenue proves, with independent and transaction-wise evidence, that an identifiable person made prohibited cash receipts breaching section 269ST. Rejected books, estimated assessments and uncorroborated admissions of additional income do not by themselves establish the statutory violation. On these principles, the penalty was held unsustainable in law. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793953