2011 (4) TMI 1302

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....e Tribunal dated 1st May 2009, raising following question for our consideration :- "Whether the Appellate Tribunal is right in law and on facts in confirming the order passed by CIT [A] in deleting the penalty of ₹ 60,97,000/= levied u/s. 271E, for violation of provisions made u/s. 269T of the Act ?" It can be seen from the question itself that the issue pertains to levy of penalty u/s. 27....

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....on is shown several years after the initial acceptance of the money in cash. The Assessing Officer thus rightly believed breach of Section 269T of the Act. We, however, find that the CIT [A] in its Order observed that there is no dispute regarding genuineness of the transactions, and the source of funds are proved and are not doubted. It was further observed that the sale and purchase were cancel....