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ITAT set aside penalty under s271DA for cash receipts exceeding Rs. 2 lakhs, finding reasonable cause in taxpayer's interpretation of s269ST's "single transaction" language. Taxpayer maintained proper documentation of agricultural sellers including Aadhar, land records and Form 60, with no evidence of tax evasion. Distinguished from s40A(3), s269SS and s269T which use "aggregate" terminology. Being first year of new provision, taxpayer's bona fide belief that limit applied per individual receipt rather than cumulative total was plausible. Following Supreme Court precedent that penalties are quasi-criminal requiring more than technical breach, ITAT deleted penalty noting proper accounting and absence of black money allegations.
ITAT set aside penalty under s271DA for cash receipts exceeding Rs. 2 lakhs, finding reasonable cause in taxpayer's interpretation of s269ST's "single transaction" language. Taxpayer maintained proper documentation of agricultural sellers including Aadhar, land records and Form 60, with no evidence of tax evasion. Distinguished from s40A(3), s269SS and s269T which use "aggregate" terminology. Being first year of new provision, taxpayer's bona fide belief that limit applied per individual receipt rather than cumulative total was plausible. Following Supreme Court precedent that penalties are quasi-criminal requiring more than technical breach, ITAT deleted penalty noting proper accounting and absence of black money allegations.
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