Section 271D Penalty applicable on Loan from Sister Concerns in Cash

In this appeal preferred by the Revenue, the dispute is regarding penalty under section 271-D of the Income Tax Act, 1961 (hereinafter referred as the “Act”) imposed for contravening the provisions of section 269-SS of the Act.

The appeal was admitted on the following substantial questions of law :–

“Whether the Income Tax Appellate Tribunal was justified in law in deleting the penalty under section 273-D of the Income Tax Act, 1961 amounting to Rs. 46,00,000

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