https://www.taxtmi.com/caselaws?id=793936 Penalty under section 271DA requires a prior, clear jurisdictional satisfaction in the assessment order that section 269ST was violated. The assessment order here did not identify the payer, transaction, date, or manner of crossing the statutory limit, so the penalty proceedings were without valid jurisdiction and unsustainable. On merits, seized tally data, statements, and estimated income showed unaccounted receipts but did not independently prove transaction-wise and person-wise receipt in contravention of section 269ST. In the absence of corroborative evidence from alleged payers, the Revenue failed to discharge its burden, and the penalty was deleted. en-us Sun, 24 May 2026 00:00:00 +0530 Fri, 26 Jun 2026 07:07:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793936 Penalty under section 271DA requires a prior, clear jurisdictional satisfaction in the assessment order that section 269ST was violated. The assessment order here did not identify the payer, transaction, date, or manner of crossing the statutory limit, so the penalty proceedings were without valid jurisdiction and unsustainable. On merits, seized tally data, statements, and estimated income showed unaccounted receipts but did not independently prove transaction-wise and person-wise receipt in contravention of section 269ST. In the absence of corroborative evidence from alleged payers, the Revenue failed to discharge its burden, and the penalty was deleted. Case-Laws Income Tax Sun, 24 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793936