https://www.taxtmi.com/caselaws?id=16687 The Court upheld the constitutionality of sections 269SS and 269T of the Income Tax Act, 1961, dismissing the writ applications challenging the penalties imposed under these sections. The Court found that penalizing only the borrower and not the lender under section 269SS is rational and not discriminatory, in line with the decisions of the Madras and Gujarat High Courts. The absence of mens rea and the argument of double jeopardy were deemed factors for Departmental authorities to consider, not affecting the validity of the sections. The Court concluded that the penalties prescribed under these sections are for different violations and do not amount to double jeopardy. en-us Thu, 09 Jan 1997 00:00:00 +0530 Wed, 09 Sep 2009 14:55:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16687 The Court upheld the constitutionality of sections 269SS and 269T of the Income Tax Act, 1961, dismissing the writ applications challenging the penalties imposed under these sections. The Court found that penalizing only the borrower and not the lender under section 269SS is rational and not discriminatory, in line with the decisions of the Madras and Gujarat High Courts. The absence of mens rea and the argument of double jeopardy were deemed factors for Departmental authorities to consider, not affecting the validity of the sections. The Court concluded that the penalties prescribed under these sections are for different violations and do not amount to double jeopardy. Case-Laws Income Tax Thu, 09 Jan 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16687