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2003 (1) TMI 46 - HC - Income Tax
"1. Whether the Income-tax Appellate Tribunal has erred in deleting the penalty imposed under section 271D of the Act by holding that the appellant did not contravene the provisions of section 269SS of the Income-tax Act? - 2. Whether the order of the Income-tax Appellate Tribunal is perverse on both law and merits?" - we are in complete agreement with the Tribunal that the provisions of section 269SS were not attracted on the facts of the case. Admittedly, neither the assessee nor IL & FS had made any payment in cash. The order of the Tribunal does not give rise to any question of law, much less a substantial question of law.