Penalty U/s 271D & 271E Deleted – Partner Capital Cash Not Covered U/s 269SS/269T: ITAT Kolkata

Amselor Commodity Trade LLP Vs ITO (ITAT Kolkata) Penalty U/s 271D & 271E Deleted – Partner Capital Introduction & Withdrawal Not Hit by Sec. 269SS / 269T – ITAT Kolkata During survey u/s 133A, AO observed cash introduction of ₹2.60 lakh each by partners in LLP & levied penalty u/s 271D alleging violation of Sec 269SS. Further, cash withdrawals of ₹3.02 lakh from partner capital accounts were treated as violation of Sec 269T & penalty u/s 271E was imposed, which was confirmed by CIT(A). ITAT held that partner capital contribution cannot be treated as loan or deposit &am...