2000 (8) TMI 17

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....manan, CJ. Heard Mr. L. M. Lodha for the Department. This appeal is filed by the Department questioning the correctness of the order passed by the Income-tax Appellate Tribunal confirming the order of the Commissioner of Income-tax (Appeals). The question posed for our consideration is whether the amount credited to the account of Ramchander Banarsidass is a deposit or a loan or a trading trans....

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....ovisions of section 269SS refer to loans or deposits. This itself, as pointed out by the Commissioner, would indicate that the Legislature had kept in view the subtle distinction between loans and deposits while framing the provisions of section 269T and section 269SS. The Income-tax Appellate Tribunal, on appeal by the Income-tax Officer, confirmed the decision of the Commissioner of Income-ta....