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    <description>Cash received as earnest money was held not to fall within the mischief of section 269SS because it was explained as temporary parking of sale proceeds by an agriculturist father without an operating bank account, and that explanation was not rebutted by the Revenue. On those facts, the receipt was not established as a loan or deposit, so the foundation for penalty under section 271D failed and the penalty was deleted.</description>
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      <description>Cash received as earnest money was held not to fall within the mischief of section 269SS because it was explained as temporary parking of sale proceeds by an agriculturist father without an operating bank account, and that explanation was not rebutted by the Revenue. On those facts, the receipt was not established as a loan or deposit, so the foundation for penalty under section 271D failed and the penalty was deleted.</description>
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