https://www.taxtmi.com/caselaws?id=61847 ITAT set aside penalties imposed under ss. 271D and 271E for alleged contravention of ss. 269SS and 269T. It held that the validity of penalty must be tested with reference to the law in force when the impugned cash transactions occurred, and that the provisions are directory, not mandatory. The fund movements between the assessee and its sister concerns were treated as internal business adjustments, not "loans" or "deposits" in the statutory sense, as there were no receipts, promissory notes or independent evidence of borrowing. Alternatively, even assuming applicability of ss. 269SS/269T, the assessee's bona fide belief and genuine transactions constituted reasonable cause, rendering penalty unsustainable. en-us Fri, 16 Apr 1993 00:00:00 +0530 Fri, 12 Dec 2025 17:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61847 ITAT set aside penalties imposed under ss. 271D and 271E for alleged contravention of ss. 269SS and 269T. It held that the validity of penalty must be tested with reference to the law in force when the impugned cash transactions occurred, and that the provisions are directory, not mandatory. The fund movements between the assessee and its sister concerns were treated as internal business adjustments, not "loans" or "deposits" in the statutory sense, as there were no receipts, promissory notes or independent evidence of borrowing. Alternatively, even assuming applicability of ss. 269SS/269T, the assessee's bona fide belief and genuine transactions constituted reasonable cause, rendering penalty unsustainable. Case-Laws Income Tax Fri, 16 Apr 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61847