2010 (9) TMI 863

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....ndent-assessee had received share application money amounting to Rs. 13,90,000 from 29 persons and the said amount was treated as loans or advances by the Assessing Officer and eventually a penalty of Rs. 13,90,000 under section 271D of the Income-tax Act, 1961 (for brevity "the Act") was imposed for certain reasons.   3. Being grieved, the assessee filed an appeal before the Commissioner of....

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....pra, learned counsel for the Revenue, has referred to question (a) as substantial question of law to be arising which emerges for consideration in this appeal. The said question reads as under :   "Whether the learned Income-tax Appellate Tribunal erred in law and on the merits in deleting the penalty under section 271D of the Income-tax Act, 1961, by holding that share application money rec....