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Acceptance or repayment of loans through journal entries was treated as a violation of the statutory requirement to use recognised banking modes, attracting exposure to penalty under sections 271D and 271E. The Tribunal held that immunity under section 273B is available only where the assessee proves reasonable cause, and on the facts no compelling business necessity, unavoidable circumstance, or contemporaneous material was shown to justify bypassing normal banking channels. Mere assertions of bona fides, genuineness, or convenience were found insufficient. The penalties were therefore upheld and the appeals were dismissed.
Acceptance or repayment of loans through journal entries was treated as a violation of the statutory requirement to use recognised banking modes, attracting exposure to penalty under sections 271D and 271E. The Tribunal held that immunity under section 273B is available only where the assessee proves reasonable cause, and on the facts no compelling business necessity, unavoidable circumstance, or contemporaneous material was shown to justify bypassing normal banking channels. Mere assertions of bona fides, genuineness, or convenience were found insufficient. The penalties were therefore upheld and the appeals were dismissed.
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