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    <title>Penalty under s.271D vacated where society&#039;s bona fide belief and mutuality meant loans from members not hit by s.269SS</title>
    <link>https://www.taxtmi.com/highlights?id=92474</link>
    <description>ITAT allowed the assessee&#039;s appeal and set aside penalty under s.271D. The Tribunal held that the CIT(A) erred in rejecting the defence of reasonable cause and applicability of the principle of mutuality; a society&#039;s bona fide belief that loans from members did not contravene s.269SS constituted a reasonable cause within the statutory scheme. Further, the impugned receipts had already been taxed, thereby losing the character of loan/deposit for penalty purposes under s.269SS, so levy of penalty under s.271D was not warranted. Result: penalty under s.271D vacated and appeal of the assessee allowed.</description>
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    <pubDate>Sat, 13 Sep 2025 08:47:17 +0530</pubDate>
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      <title>Penalty under s.271D vacated where society&#039;s bona fide belief and mutuality meant loans from members not hit by s.269SS</title>
      <link>https://www.taxtmi.com/highlights?id=92474</link>
      <description>ITAT allowed the assessee&#039;s appeal and set aside penalty under s.271D. The Tribunal held that the CIT(A) erred in rejecting the defence of reasonable cause and applicability of the principle of mutuality; a society&#039;s bona fide belief that loans from members did not contravene s.269SS constituted a reasonable cause within the statutory scheme. Further, the impugned receipts had already been taxed, thereby losing the character of loan/deposit for penalty purposes under s.269SS, so levy of penalty under s.271D was not warranted. Result: penalty under s.271D vacated and appeal of the assessee allowed.</description>
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      <pubDate>Sat, 13 Sep 2025 08:47:17 +0530</pubDate>
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