Leviability of Penalty under section 271D if Assessee have reasonable cause for borrowing in violation of section 269SS

RELEVANT PARAGRAPH

. The following point of difference has been referred to me u/s 255(4) of the IT Act for decision:

“Whether on the facts and in the circumstances of the case, penalty u/s.271D of the Income-tax Act, 1961 is leviable?

2. The facts leading up to the levy of penalty have been stated in the dissenting orders and there is no dispute regarding their accuracy. The only ques

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