Section 269SS not applicable to transactions between relatives

Snehalata Sitani Vs JCIT (ITAT Kolkata) The learned counsel for the assessee, on the other hand, has contended that the provisions of section 269SS are not strictly applicable to the transactions between the relatives and the penalty imposed by the assessing officer under section 271D and confirmed by the learned Commissioner(Appeals) is not sustainable. In support of this contention, he has relied on the decision of the Coordinate Bench of this Tribunal rendered in the case of Manisha Prakash Amin v. Jt. CIT vide its order dated 24-5-2011 passed in ITA No. 1839/Kol/2010, wherein it was h...