https://www.taxtmi.com/caselaws?id=449183 The ITAT Indore dismissed revenue appeals challenging penalty deletions under sections 271D and 271E. The penalties were imposed based on alleged cash loan transactions discovered during a search operation under section 132 involving the PATH Group, where the assessee served as managing director. The ITAT adopted the same reasoning from a previous PATH Group case where both the first appellate authority and ITAT had rejected the assessing authority's conclusions. The tribunal held that penalties under sections 269SS and 269T cannot apply when the existence of transactions themselves are disputed, as these provisions only govern undisputed or finalized transactions. The CIT(A)'s order deleting penalties was upheld. en-us Wed, 31 Jan 2024 00:00:00 +0530 Tue, 06 Feb 2024 09:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449183 The ITAT Indore dismissed revenue appeals challenging penalty deletions under sections 271D and 271E. The penalties were imposed based on alleged cash loan transactions discovered during a search operation under section 132 involving the PATH Group, where the assessee served as managing director. The ITAT adopted the same reasoning from a previous PATH Group case where both the first appellate authority and ITAT had rejected the assessing authority's conclusions. The tribunal held that penalties under sections 269SS and 269T cannot apply when the existence of transactions themselves are disputed, as these provisions only govern undisputed or finalized transactions. The CIT(A)'s order deleting penalties was upheld. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449183