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    <title>2026 (7) TMI 791 - ITAT MUMBAI</title>
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    <description>A receipt accepted on the Revenue&#039;s own premise as a cash loan cannot simultaneously be treated as taxable income merely because the loan was received in contravention of Section 269SS of the Income-tax Act, 1961. The statutory scheme addresses such non-compliant acceptance through the specific penalty provision under Section 271D. The legal point is that violation of the prescribed mode of accepting a loan does not change the receipt&#039;s character into assessable income. The notes state that, on this reasoning, the disputed addition was considered unsustainable and removed in favour of the assessee.</description>
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    <pubDate>Mon, 29 Jun 2026 00:00:00 +0530</pubDate>
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      <title>2026 (7) TMI 791 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=794905</link>
      <description>A receipt accepted on the Revenue&#039;s own premise as a cash loan cannot simultaneously be treated as taxable income merely because the loan was received in contravention of Section 269SS of the Income-tax Act, 1961. The statutory scheme addresses such non-compliant acceptance through the specific penalty provision under Section 271D. The legal point is that violation of the prescribed mode of accepting a loan does not change the receipt&#039;s character into assessable income. The notes state that, on this reasoning, the disputed addition was considered unsustainable and removed in favour of the assessee.</description>
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      <pubDate>Mon, 29 Jun 2026 00:00:00 +0530</pubDate>
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