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2024 (2) TMI 789 - ITAT DELHIPenalty u/s 271D - accepting cash loan of Rs. 2 lakh in aggregate without any reasonable cause in contravention to section 269SS - transactions between father and son - HELD THAT:- No cogent reasons have been assigned either by the Ld. Addl. CIT and / or the Ld. CIT(A) to reject the assessee’s explanation. It is not disputed that the transaction took place between the assessee and his son, both carrying on their independent business. Confirmed copies of account of the assessee in the books of concern of his son and vice versa were brought on record. Genuineness of transaction has not been doubted. All the transactions were accounted for by the assessee and his son in their respective books of account. The impugned transaction is reportedly to meet business exigency. We are therefore of the opinion that the assessee established the existence of reasonable cause for the impugned transaction and therefore the penalty is not exigible. Decided in favour of assessee.
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