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    <title>2026 (4) TMI 555 - ITAT DELHI</title>
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    <description>Penalty under section 271D could not be sustained where the impugned loan receipts were shown to have been made through banking channels and placed in an earlier financial year, so no cash transaction in contravention of section 269SS was established. Penalty under section 271(1)(c) was also not justified because the business loss claim was based on disclosed audited accounts and associated business records; mere acceptance of disallowance did not by itself prove furnishing of inaccurate particulars. On those facts, both penalties were deleted and the assessee received full relief.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789486</link>
      <description>Penalty under section 271D could not be sustained where the impugned loan receipts were shown to have been made through banking channels and placed in an earlier financial year, so no cash transaction in contravention of section 269SS was established. Penalty under section 271(1)(c) was also not justified because the business loss claim was based on disclosed audited accounts and associated business records; mere acceptance of disallowance did not by itself prove furnishing of inaccurate particulars. On those facts, both penalties were deleted and the assessee received full relief.</description>
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      <pubDate>Wed, 25 Mar 2026 00:00:00 +0530</pubDate>
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