In absence of source of cash loans, provisions of section 269SS/ 269T not applicable

Ravinder Shivhare Vs ACIT (ITAT Indore) ITAT Indore held that as AO unable to found source of any cash loans during the search proceedings, provisions of section 269SS/ 269T of the Income Tax Act cannot be applied. Facts- A search u/s 132 was conducted on 07.01.2016 upon assessee wherein two documents inventorised as “LPS-01-Page 135” and “LPS-02-Page 48” were seized. Based on “LPS-01-Page 135”, the AO framed a view that the assessee had taken/repaid cash-loans from/to Shri Laxmi Narayan Shivhare and based on “LPS-02-Page 48”, he formed a view that the assessee had taken/repaid...