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of <h1>Legal Victory: Tax Authorities Lose Case as Promissory Notes Distinguish from Traditional 'Hundi' Financial Instruments Under Section 69D</h1> <h3>Commissioner of Income-tax Versus Jaya Stores</h3> Commissioner of Income-tax Versus Jaya Stores - TMI The Madras High Court addressed two legal questions regarding section 69D of the Income-tax Act, 1961: (1) whether the provisions apply to 'hundi' loans not made through account payee cheques, and (2) whether documents executed by the assessee in favor of creditors qualify as 'hundi' under section 69D. Relying on the precedent in CIT v. Paranjothi Salt Co. [1995] 211 ITR 141, the Court upheld the Tribunal's factual finding that the documents were promissory notes (pronotes), not hundies. Consequently, the Court held that the Tribunal was correct in law and declined to interfere, answering both questions in favor of the assessee and against the revenue.
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