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2017 (2) TMI 1507 - AT - Income TaxPenalty u/s.271D - assessee received cash loans from his two partnership firms - violation u/s 269SS - proof of bonafied belief - whether transactions between a firm and partner do not attract the rigor of 269SS and 269T? - HELD THAT:- Revenue fails to dispute all the stated decisions holding that Section 269SS is not attracted in transactions between a partnership firm and its partner not partaking the character of a loan and deposit in general law as held in another co-ordinate bench decision in ITO vs. Bharat kumar Dayaram Patel[2010 (10) TMI 1228 - ITAT AHMEDABAD]. We accordingly draw support therefrom and uphold the CIT(A)’s order under challenge deleting Section 271D penalty in question. - Decided against revenue.
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