2000 (8) TMI 17

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..... the Department questioning the correctness of the order passed by the Income-tax Appellate Tribunal confirming the order of the Commissioner of Income-tax (Appeals). The question posed for our consideration is whether the amount credited to the account of Ramchander Banarsidass is a deposit or a loan or a trading transaction? The Commissioner of Income-tax (Appeals), on a detailed consideration .....

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..... t by the Commissioner, would indicate that the Legislature had kept in view the subtle distinction between loans and deposits while framing the provisions of section 269T and section 269SS. The Income-tax Appellate Tribunal, on appeal by the Income-tax Officer, confirmed the decision of the Commissioner of Income-tax (Appeals). Both the Commissioner (Appeals) as well as the Appellate Tribunal, .....

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