2011 (2) TMI 1188

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....IR   J U D G M E N T   Ramachandran Nair, J.   This appeal is filed by the Revenue challenging the order of the Tribunal cancelling penalty levied on the respondent assessee under Section 271D for violation of Section 269SS of the Income Tax Act (hereinafter referred to as the Act for short).   2. We have heard Shri.P.K.R.Menon, learned Senior counsel appearing for ....

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....l for the Revenue contended that the explanation of the assessee, which was accepted by the Tribunal, that it is on account of ignorance of law that he borrowed money from individuals, is not tenable. Learned counsel appearing for the assessee, on the other hand, referred to the findings of the Assessing Officer in the penalty order itself, wherein the source of lenders as borrowings from Banks is....