TMI Blog2014 (1) TMI 1874X X X X Extracts X X X X X X X X Extracts X X X X ..... ERABAD] . It appears that the assessee challenged the penalty proceedings initiated under Section 271D of the Income Tax Act, 1961 on the ground of illegal borrowings in contravention of Section 269SS of the Act. The learned Tribunal on an earlier occasion found that there is no proof of receipt of such loan from the records and they were only found to be journal entries. The learned Tribunal, in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case and in law, the Hon ble Income Tax Appellate Tribunal is justified in holding that the transactions through journal entry do not attract the provisions of Section 269SS and consequently penalty is not leviable under Section 271D of the Income Tax Act, 1961 ? 2. Whether Income Tax Appellate Tribunal is justified in holding that the assessee has accepted the loan only by journal entr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... levant findings of the previous judgment have been extracted and there is no dispute that the same is accurate or incorrect. Hence, we can safely rely on the same. We have read the reasoning rendered in the previous judgment. It appears that the assessee challenged the penalty proceedings initiated under Section 271D of the Income Tax Act, 1961 on the ground of illegal borrowings in cont ..... X X X X Extracts X X X X X X X X Extracts X X X X
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