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        Case ID :
        Income Tax

        Assessee made repayments of loans/deposits through modes other...

        Loan/deposit repayments via non-account payee modes breach Sec 269T; penalty u/s 271E deleted for CSA dues adjusted against deposits.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Assessee made repayments of loans/deposits through modes other than account payee cheques/drafts, violating Section 269T. Penalty u/s 271E was imposed. ITAT bifurcated transactions into those with related parties and Customer Sales Agents (CSAs). For CSA transactions, outstanding dues were adjusted against security deposits through journal entries, breaching Section 269SS. However, ITAT held this constituted 'reasonable cause' u/s 273B, not attracting penalty u/s 271E, relying on Ajitnath Hi-Tech Builders (P.) Ltd. [2018 (2) TMI 603 - Bombay HC]. Consequently, ITAT set aside CIT(A)'s order and directed AO to delete penalty levied u/s 271E, deciding in favor of assessee.
                                Note: It is a system-generated summary and is for quick reference only.
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