Section 269SS not applies to loan between firm and partners

Loan between firm and partners is out of ambit of Section 269SS Facts of the Case- During the course of the assessment proceedings, it was found that the firm had accepted payments from the partners, during the relevant year corresponding to the Assessment Years, in cash. The details of the total amounts paid to the individual firm by the partners in all the aforesaid four appeals are as under: Appeal No. Amount of advance made by the partners Assessment Year Amount of Penalty ITA No. 336/2002 Rs. 2,08,45,000/- 1996-97 Rs.2,08,45,000/- ITA No. 338/2002 Rs.2,29,34,000/- 1998-99 Rs.2,29,3...