No penalty u/s 271DA as there was no proof of section 269ST violation

Shreemukh Realtors Vs DCIT/ACIT (ITAT Hyderabad) Conclusion: Penalty under section 271DA could not be sustained merely on the basis of unverified seized data without independent corroborative evidence. Revenue must conclusively establish violation of section 269ST, and where assessee had disclosed the income and paid due taxes, penalty was not automatic and must satisfy the test of reasonableness and statutory conditions. Held: During a search, Revenue relied on Tally data found in a seized pen drive to allege that assessee had accepted cash exceeding the threshold prescribed under section 269...