https://www.taxtmi.com/caselaws?id=214038 Whether journal entries constitute "repayment" under s.269T attracting penalty under s.271E: The court construed ss.269T, 271E and 273B together, holding that s.269T prohibits repayment except by prescribed modes and non-compliance prima facie renders one liable to penalty under s.271E; however, where repayment by book-adjustment reflected bona fide commercial adjustment (sale proceeds due to the payer) and was not disbelieved in assessment, the transaction did not evidence tax-evasion. Outcome: journal entries alone did not sustain penalty. Whether s.273B reasonable cause defense exempted penalty: Given absence of mala fides and regularity in books, reasonable cause under s.273B was made out; Outcome: penalty under s.271E deleted. en-us Tue, 12 Jun 2012 00:00:00 +0530 Tue, 13 Jan 2026 14:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214038 Whether journal entries constitute "repayment" under s.269T attracting penalty under s.271E: The court construed ss.269T, 271E and 273B together, holding that s.269T prohibits repayment except by prescribed modes and non-compliance prima facie renders one liable to penalty under s.271E; however, where repayment by book-adjustment reflected bona fide commercial adjustment (sale proceeds due to the payer) and was not disbelieved in assessment, the transaction did not evidence tax-evasion. Outcome: journal entries alone did not sustain penalty. Whether s.273B reasonable cause defense exempted penalty: Given absence of mala fides and regularity in books, reasonable cause under s.273B was made out; Outcome: penalty under s.271E deleted. Case-Laws Income Tax Tue, 12 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214038