Section 271D/271E Penalty Fails once Quantum Additions Deleted for Cash Loan Violations

ACIT Vs Saurabh Gupta (ITAT Agra)

The Income Tax Appellate Tribunal, Agra dismissed the Revenue’s appeals and upheld deletion of penalties levied under sections 271D and 271E of the Income-tax Act, 1961, holding that penalties cannot survive independently when the underlying quantum additions have been deleted. The case related to Assessment Year 2015–16, where assessment was completed under section 143(3) read with section 153C following a search under section 132 in BNR Group cases. During assessment, the Assessing Officer treated alleged cash loans received and repaid as une

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