ITAT dismissed the appeal, upholding the penalty under Section...

ITAT dismissed the appeal, upholding the penalty under Section 271D for accepting cash loans/deposits in violation of Section 269SS. The tribunal found no substantive evidence supporting the appellant's claim of bona fide belief or reasonable cause for cash transactions. The appellant failed to establish factual foundations demonstrating why the statutory provisions were inapplicable. The tribunal emphasized that mere assertions without concrete proof cannot negate the penalty. Consequently, the lower authorities' orders were confirmed, and the appeal was dismissed, maintaining the imposed penalty for non-compliance with statutory cash transaction restrictions.