Penalty Us/ 271D applies only when Assessee accepts cash Loan Exceeding Rs. 20,000/- from a person

Facts are exactly identical what was before the Hon’ble Bombay High Court (supra) and in each of case cash loan is not exceeding Rs. 20,000/- rather it is exactly Rs. 20,000/-. Since there is a circular and which is a beneficial circular under section 269SS of the Act and Hon’ble Bombay High Court has interpreted circular no. 572 dated 3rd August 1990 (supra) wherein vide para 3 relevant portion of clause 43 is as under: “43. Secs. 271C, 271D and 271E, which were inserted in the I T Act w.e.f. 1st April, 1989, by the Direct Tax Laws (Amendment) Act, 1987, provided for the lev...