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 which was levied on account of violation of section 269-SS of the Income Tax Act, 1961 on the technical ground without going...