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2015 (3) TMI 19 - HC - Income TaxPenalty u/s 271D - contravention of the provision under Section 269SS - whether the explanation given by the assessee has a reasonable cause to embark on such transaction, which would fall within the provisions of Section 269SS? - Held that:- Though several documents have been submitted by the assessee, there is nothing to show that there was urgency for the assessee to avail the loan in cash in violation of Section 269SS and that the Assessing Officer has given a detailed reasoning as to why he finds that such a transaction would not come under the exception clause of Section 271D of the Income Tax Act. The Tribunal has confirmed the said finding of fact. Being a pure finding of fact, we find no reason to interfere with the order of the Tribunal. In fact, the assessee himself has relied on the decisions of this Court in the case of Commissioner of Income -Tax V. Balaji Traders reported in (2006 (12) TMI 126 - MADRAS HIGH COURT) and in the case of Commissioner of Income-Tax V. Deccan Designs (India) P. Ltd. reported in (2010 (7) TMI 818 - Madras High Court) wherein this Court clearly held that unless there is any inconsistency in the finding of fact arrived at by the Tribunal or the Authorities concerned, the Court should not interfere with such a finding of fact. - Decided against assessee.
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