ITAT upheld the assessee's appeal, finding no justifiable basis...

ITAT upheld the assessee's appeal, finding no justifiable basis to reclassify share application money as loans/deposits under Section 269SS. The Tribunal relied on the jurisdictional High Court's precedent, which clarified that share application money does not fall under loan or deposit provisions. Consequently, the penalty under Section 271D was not leviable. The decision affirmed the CIT(A)'s order deleting the penalty, emphasizing strict interpretation of taxing statutes and procedural requirements in penalty proceedings.