Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (6) TMI 332 - AT - Income TaxPenalty u/s 271D - contravention of provisions of Section 269SS - Cash transaction between the Company and its Director - a. cash utilized for purchase of stamps - b. cash deposited in the bank account of the compnay by the Director - challenging the categorization of transaction as ‘loan or deposit’ when there is no element of any interest - HELD THAT:- No reasonable cause or urgency is shown by the assessee for having accepted cash on different occasions from the Director. It could not be shown as to why the transactions could not be undertaken in compliance with the prescribed modes u/s 269SS. Further, the Private Limited company and Director are altogether different person under the provisions of Section 2(31), and there could not be two view on this. CIT-DR has rightly relied upon judicial precedents to support his contentions, which we have reproduced in preceding para’s of this order, and the same are not repeated again. Thus, keeping in view our aforesaid discussions as above, we uphold the penalty levied by ld. JCIT and as upheld by ld.CIT(A). The appeal filed by the assessee stand dismissed.
|