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Commissioner Of Income Tax vs Lokhpat Film Exchange (Cinema) on 23 January, 2007

"6.10 Entry dated 14.11.2007 of Rs.25,00,000/- in the name of M/s Dewana Dairy : The facts in this regard are that M/s Vardaan Fashion, a partnership firm in which the appellant was a partner, paid Rs.25,00,000/- vide an account payee cheque no.498989 dated 14.11.2007 to M/s Dewana Dairy on behalf of the appellant. These transactions were business transactions and to prove it the appellant had filed copy of account of M/s Vardaan Fashion and M/s Dewana 29 ITA-2253/D/2013 & 5 others Dairy in the books of the appellant and the ledger account of the appellant in the books of M/s Vardaan Fashion. Under the Indian Partnership Act, the partnership firm is not a juristic person and it works through its partners. Any payment made by the firm amounts to the payment made by the partner. Since, the partner and his partnership firm is one and the same person in the eye of law, there is no legality in making the payment by the firm on behalf of his partner. Hence, the provisions of section 269T do not apply to the transaction in question. The AR of the appellant in support of his case relied on the judgments of the Hon'ble High Court of Rajasthan in the case of CIT vs. Lokhpat Film Exchange (Cinema) (2008) 304 ITR 172 and of the ITAT A-Bench Ahmedabad in the case of Shrepak Enterprises vs. Deputy Commissioner of Income-tax (1998) 60 TTJ 199. Even otherwise, there was no contravention of the provisions of section 269T as the repayment was made only through an account payee cheque.
Rajasthan High Court - Jaipur Cites 8 - Cited by 26 - Full Document

Income Tax Officer vs Tarlochan Singh on 16 December, 2002

60. After considering the facts of the case and the arguments of both the sides, we do not find any infirmity in the order of learned CIT(A). Smt. Nirupama Wadhawan is the wife of the assessee who had some surplus cash which she gave to the assessee because the assessee and his wife intended to jointly purchase a house property. Smt. Nirupama Wadhawan had given the surplus cash available with her for the purpose of purchase of such house property. However, when the deal for purchase of the house property could not be materialized, the said amount was refunded to her through cheque. We find that the similar issue was considered by ITAT, Amritsar Bench in the case of ITO Vs. Tarlochan Singh - [2003] 128 Taxman 20 (Mag.). In the said case, the husband had taken the cash of `70,000/- from his wife for the purpose of investment in the acquisition of immovable property. The Assessing Officer had levied the penalty under Section 271D which was cancelled by the ITAT holding as under :-
Income Tax Appellate Tribunal - Amritsar Cites 7 - Cited by 6 - Full Document
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