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    <title>2026 (5) TMI 414 - ITAT KOLKATA</title>
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    <description>Cash receipts alleged to be loans or deposits under section 269SS were not conclusively shown on the record to be such, because the assessee claimed they were repayments of earlier advances to farmers and the supporting evidence was not available before the Tribunal. The penalty issue under section 271D was therefore remanded for fresh adjudication, with the assessee to be given an opportunity to produce material and seek relief under section 273B if reasonable cause is established. The challenge to the initiation notice for absence of DIN failed, as the Tribunal noted the retrospective clarificatory provision and also recorded that the notice carried a DIN.</description>
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      <title>2026 (5) TMI 414 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=791212</link>
      <description>Cash receipts alleged to be loans or deposits under section 269SS were not conclusively shown on the record to be such, because the assessee claimed they were repayments of earlier advances to farmers and the supporting evidence was not available before the Tribunal. The penalty issue under section 271D was therefore remanded for fresh adjudication, with the assessee to be given an opportunity to produce material and seek relief under section 273B if reasonable cause is established. The challenge to the initiation notice for absence of DIN failed, as the Tribunal noted the retrospective clarificatory provision and also recorded that the notice carried a DIN.</description>
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