Levy of penalty u/ss 271D and 271E was challenged - default u/ss...

Levy of penalty u/ss 271D and 271E was challenged - default u/ss 269SS and 269T - assessee received and repaid cash loans from directors and related concerns - assessee contended cash was received to meet urgent expenses at project site when funds were unavailable - argument that cash loans from directors were exempt from sections 269SS and 269T rejected as no such exception exists in statute - limitation argument rejected as proceedings completed within statutory limit - delay due to COVID-19 pandemic excluded - penalty levy inappropriate given assessee's business requiring frequent expenditure at distant project site and possibility of cash loans from directors due to exigency - appeals allowed by deleting penalties.