https://www.taxtmi.com/caselaws?id=17269 HC held that sections 269T and 276E are penal provisions to be strictly construed and that the term "deposit" in section 269T is distinct from a mere loan. Repayments of loans in cash do not automatically attract the penal provisions applicable to deposits; the cause of action for loans arises at the date of loan while for deposits it arises on demand. Where two interpretations exist, the one removing an assessee from penal liability is preferred, so liability cannot be extended by stretching "deposit" to cover loans. en-us Tue, 25 Nov 1997 00:00:00 +0530 Sat, 11 Oct 2025 09:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17269 HC held that sections 269T and 276E are penal provisions to be strictly construed and that the term "deposit" in section 269T is distinct from a mere loan. Repayments of loans in cash do not automatically attract the penal provisions applicable to deposits; the cause of action for loans arises at the date of loan while for deposits it arises on demand. Where two interpretations exist, the one removing an assessee from penal liability is preferred, so liability cannot be extended by stretching "deposit" to cover loans. Case-Laws Income Tax Tue, 25 Nov 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17269