https://www.taxtmi.com/caselaws?id=794398 Penalty under section 271DA requires a clear, contemporaneous satisfaction in the assessment order that section 269ST was violated; a later notice or penalty order cannot cure that defect, so the initiation failed for want of jurisdictional satisfaction. On merits, the Revenue must independently prove transaction-wise receipt of cash from an identifiable person in a day, single transaction, or relation to one event or occasion; seized tally data, estimated income, and general admissions were insufficient without corroboration from alleged payers. Rejection of books and income estimation did not justify selective use of the same material for penalty. The penalty was therefore deleted. en-us Wed, 24 Jun 2026 00:00:00 +0530 Sat, 04 Jul 2026 08:15:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794398 Penalty under section 271DA requires a clear, contemporaneous satisfaction in the assessment order that section 269ST was violated; a later notice or penalty order cannot cure that defect, so the initiation failed for want of jurisdictional satisfaction. On merits, the Revenue must independently prove transaction-wise receipt of cash from an identifiable person in a day, single transaction, or relation to one event or occasion; seized tally data, estimated income, and general admissions were insufficient without corroboration from alleged payers. Rejection of books and income estimation did not justify selective use of the same material for penalty. The penalty was therefore deleted. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794398