Towers Pvt Ltd, all the appellants have violated the provisions of
section 269SS of the Act, thereby exposing them to the penal
provisions of section ... income of the assessee
15
u/s 68 of the Act, whether the initiation of proceedings u/s 269SS r.w.s
271D
having held that the assessee had
contravened the provisions of section 269SS of the Income
Tax Act, 1961, ought to have upheld the levy ... reasonable cause u/s. 273B , therefore, imposed a
penalty u/s 271D of Rs. 38,09,55,274/- and u/s. 271E
take action against the
assessee for infringement of Section 269SS of the IT Act, 1961
on the basis of alleged document on the basis ... take action
against assessee for infringement of Section 269SS .
4. That CIT (Appeals) has grossly erred in law and on facts in
holding that
proposed to levy the penalty u/s 271D of the
Act for the violation of the provision of section 269SS ... unsecured loan from his father in
contravention to the provisions of section 269SS of the Act. Accordingly the
AO levied the penalty
Range-2, Rajkot on account of alleged contravention of provision of section 269SS of the
Act. The penalty being totally unjustified on facts as also ... squarely by the provisions of section 271D of the IT act, 1961 for contravention of provisions in
section 269SS of the IT Act, 1961. Therefore
duly submitted before the A.O. & JCIT.
Therefore violation of Sec. 269SS does not attract. Therefore
imposition of penalty ... cash.
Further Section 271D provides that a person takes or accepts any loan or
deposit in contravention of the provisions of section 269SS
under section 271D by holding that the assessee has taken loan of Rs. 15
crores in cash in violation of provisions of section 269SS ... Kota.
proceedings under section 271D are initiated and penalty is levied generally when
the transaction of violation of provisions of section 269SS
levied
by the AO u/s. 271D for violation of provisions of section 269SS of the
I.T. Act, 1961."
ITA NO. 3081 ... appellant, I hold that no penalty u/s. 271D for violation
of the provisions of section 269SS is leviable in this
case. Accordingly, the penalty
involved i.e. the imposition of penalty
under section 271D for violation of provision of section 269SS of
the Act was decided in favour ... imposing penalty upon the respondents
under Section 271D of the Act for breach of Section 269SS of the Act. This penalty
was imposed inasmuch
opened vide notice
under section 148 dated 11.09.2013. The assessment was completed under
section 147 r.w. section 143(3) on 30/03/2015 determining ... imposing penalty upon the respondents under Section 271D of the Act
for breach of Section 269SS of the Act. This penalty was imposed inasmuch
