No 271D Penalty Without Clear Finding of 269SS Violation: ITAT Deletes ₹1 Crore Penalty

Patel Prakashchandra Ambalal HUF Vs ACIT (ITAT Ahmedabad) The Ahmedabad ITAT deleted massive penalty of ₹1.01 crore levied under Section 271D against an HUF engaged in finance and investment activities, holding that penalty for alleged cash loan/deposit transactions cannot survive in absence of clear finding regarding contravention of Section 269SS during assessment proceedings. The assessee was engaged in advancing loans and recovering the same along with interest. During revenue audit, the department alleged that the assessee had accepted cash loans/deposits in violation of Section 269SS b...