ITAT upholds CIT(A)'s deletion of penalty under section 271D, concluding that the A.O.'s and A.CIT's reliance on an asserted cash payment of Rs. 25 crores by the assessee to a third party for AY 2012-13 was erroneous. Tribunal finds absence of any evidentiary basis for actual cash receipt, negating contravention of section 269SS and precluding levy of penalty under section 271D. Consequently, CIT(A)'s deletion of the penalty is sustained and the Revenue's ground is rejected. The assessment and penalty orders insofar as they depend on the alleged cash transaction are annulled.
ITAT upholds CIT(A)'s deletion of penalty under section 271D, concluding that the A.O.'s and A.CIT's reliance on an asserted cash payment of Rs. 25 crores by the assessee to a third party for AY 2012-13 was erroneous. Tribunal finds absence of any evidentiary basis for actual cash receipt, negating contravention of section 269SS and precluding levy of penalty under section 271D. Consequently, CIT(A)'s deletion of the penalty is sustained and the Revenue's ground is rejected. The assessment and penalty orders insofar as they depend on the alleged cash transaction are annulled.
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