https://www.taxtmi.com/caselaws?id=797161 Penalty under Section 271DA for alleged cash receipt contrary to Section 269ST cannot survive where the sole quantum addition was deleted because the assessee was not involved in the underlying transaction. Establishing an actual cash receipt by the assessee is essential. Presumptions relating to seized material do not apply where the material was recovered from another entity's premises, did not refer to the assessee, and lacked supporting admission. A pending further appeal against the quantum deletion does not alter the operative effect of existing appellate findings without a stay. The penalty was therefore unsustainable and deleted. en-us Mon, 10 Aug 2026 00:00:00 +0530 Tue, 18 Aug 2026 08:35:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797161 Penalty under Section 271DA for alleged cash receipt contrary to Section 269ST cannot survive where the sole quantum addition was deleted because the assessee was not involved in the underlying transaction. Establishing an actual cash receipt by the assessee is essential. Presumptions relating to seized material do not apply where the material was recovered from another entity's premises, did not refer to the assessee, and lacked supporting admission. A pending further appeal against the quantum deletion does not alter the operative effect of existing appellate findings without a stay. The penalty was therefore unsustainable and deleted. Case-Laws Income Tax Mon, 10 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797161