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of The HC affirmed the penalty under section 271D for contravention of section 269SS, holding that the assessee's appeal fails because the purported loan was not accepted as genuine and had been treated as income under section 68. The court found the appellant's arguments devoid of merit and held that non-acceptance of the loan does not negate the imposition of penalty where cash receipts were returned/deposited in the manner alleged. The question of law was answered against the appellant and in favour of the Revenue; the penalty is sustained and the appeal is dismissed with no relief to the appellant.
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