Consequential cash-receipt penalty fails when the underlying addition is deleted and seized material does not implicate the assessee.

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....Penalty for cash receipts under section 271DA requires proof that the assessee received cash in breach of section 269ST. Where the underlying quantum addition was deleted because the alleged transaction involved other parties and not the assessee, no factual basis remained for a consequential penalty; deletion of the penalty was therefore upheld. The presumptions under sections 132(4A) and 292C apply against the person from whose possession or control seized material is found. A WhatsApp screenshot recovered from another entity's premises, without the assessee's name or admission of cash receipt, could not support a presumption against the assessee. The Revenue's appeal was dismissed.....