2018 (5) TMI 1313

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.... 1. This appeal of the revenue arises out of the order for the Asst Year 2009-10 of the Learned Commissioner of Income Tax (Appeals)-6, Kolkata [in short the Ld. ITA] in Appeal No. 208/CIT(A)-6/Kol/15-16 dated 02.11.2016 against the order passed by the J.C.I.T- Range-24, Hooghly [ in short the ld AO] under section 271D of the Act dated 30.10.2015 for the Asst Year 2009-10. 2. The only issue to b....

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....ng 100% of the loan amount would be exigible in the instant case. The ld. AO accordingly levied penalty u/s 271D of the Act. 4. The ld. CIT(A) observed that introduction of capital contributed by a partner in the partnership firm does not fall under the ambit of loan or deposit within the meaning of section 269SS of the Act. Moreover, he observed that the partner has duly reflected this introduct....