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2021 (7) TMI 1102 - AT - Income TaxPenalty u/s 271E - contravention of the provision of section 269T of the Act for repayment of loan in cash exceeding the permissible limit - Assessee argued no proper satisfaction was recorded by the assessing officer - HELD THAT:- AO erred in levying penalty u/s 271E of the Act in the case of assessee as firstly revenue failed to prove whether assessee actually received any cash loan or repaid any cash loan from R.C. Upadhya and secondly Ld. AO was not having any jurisdiction to levy the penalty as no assessment proceedings were pending in the case of assessee and thus no satisfaction was recorded by the ld. AO to initiate the penalty. Thus, finding of ld. CIT(A) is set aside and Ld. AO is directed to delete the penalty - Decided in favour of assessee.
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