https://www.taxtmi.com/caselaws?id=66127 The Tribunal held that the Addl. CIT had jurisdiction to levy penalty under s.271D by virtue of s.120; the penalty could not be annulled on want of authority. It further held that limitation under s.275 runs from the original initiation of penalty proceedings and reinitiation is impermissible; since initiation was on 21-03-1997 and penalty was imposed on 24-03-1998, the penalty was time-barred and liable to be quashed. Independently, it held that s.269SS targets cash loans used to explain unaccounted money, and genuine, disclosed transactions undertaken for business exigency did not constitute a "loan" attracting s.269SS; consequently s.271D could not apply. In any event, "reasonable cause" and the quasi-criminal nature of penalty warranted deletion; the penalty was deleted and the appeal allowed. en-us Mon, 17 Sep 2001 00:00:00 +0530 Tue, 06 Jan 2026 21:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66127 The Tribunal held that the Addl. CIT had jurisdiction to levy penalty under s.271D by virtue of s.120; the penalty could not be annulled on want of authority. It further held that limitation under s.275 runs from the original initiation of penalty proceedings and reinitiation is impermissible; since initiation was on 21-03-1997 and penalty was imposed on 24-03-1998, the penalty was time-barred and liable to be quashed. Independently, it held that s.269SS targets cash loans used to explain unaccounted money, and genuine, disclosed transactions undertaken for business exigency did not constitute a "loan" attracting s.269SS; consequently s.271D could not apply. In any event, "reasonable cause" and the quasi-criminal nature of penalty warranted deletion; the penalty was deleted and the appeal allowed. Case-Laws Income Tax Mon, 17 Sep 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66127