Assessee's Loan Misclassification as Trust Funds Fails; Penalty Imposed u/s 271D Due to Financial Statement Inconsistency.

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....Penalty under section 271D - Though the assessee has made an endavour to project the loan taken as amount received as a trustee by virtue of power of attorney but, in our view, such plea of the assessee is on thin ground. Had it been a case of holding the money of the lady in trust, the assessee would not have shown it as loan in its books of account and financial statement. - AT....