https://www.taxtmi.com/caselaws?id=216749 Cash received as share application money or share capital from directors was treated as distinct from a loan or deposit because there was no repayment obligation, interest, or other lending features. On that basis, section 269SS was not attracted and penalty under section 271D was not leviable. The commentary also notes that where the transactions were genuine, involved promoters or directors, and showed no tax-evasive intent, the bona fide nature of the receipt constituted reasonable cause under section 273B. In such circumstances, any procedural infraction was considered technical rather than mala fide, and the penalty cancellation was upheld. en-us Thu, 06 Sep 2012 00:00:00 +0530 Wed, 19 Sep 2012 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216749 Cash received as share application money or share capital from directors was treated as distinct from a loan or deposit because there was no repayment obligation, interest, or other lending features. On that basis, section 269SS was not attracted and penalty under section 271D was not leviable. The commentary also notes that where the transactions were genuine, involved promoters or directors, and showed no tax-evasive intent, the bona fide nature of the receipt constituted reasonable cause under section 273B. In such circumstances, any procedural infraction was considered technical rather than mala fide, and the penalty cancellation was upheld. Case-Laws Income Tax Thu, 06 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216749