https://www.taxtmi.com/caselaws?id=71524 ITAT Pune allowed the assessee's appeal and deleted the penalty imposed u/s 271D. It held that s.269SS applies only where there is an actual taking or accepting of "loan or deposit" involving transfer of money from one person to another. Mere acknowledgement of an already incurred debt by passing a journal entry in the books, without any fresh monetary inflow, does not constitute a "loan" or "deposit" within the meaning of s.269SS. Being a penal provision, s.271D must be construed strictly, and in case of ambiguity, the interpretation favourable to the assessee must prevail. The order of the CIT(A) sustaining the penalty was set aside. en-us Fri, 10 Jan 1997 00:00:00 +0530 Sun, 14 Dec 2025 23:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71524 ITAT Pune allowed the assessee's appeal and deleted the penalty imposed u/s 271D. It held that s.269SS applies only where there is an actual taking or accepting of "loan or deposit" involving transfer of money from one person to another. Mere acknowledgement of an already incurred debt by passing a journal entry in the books, without any fresh monetary inflow, does not constitute a "loan" or "deposit" within the meaning of s.269SS. Being a penal provision, s.271D must be construed strictly, and in case of ambiguity, the interpretation favourable to the assessee must prevail. The order of the CIT(A) sustaining the penalty was set aside. Case-Laws Income Tax Fri, 10 Jan 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71524