No Penalty u/s 271E for Cash Repayment of Deposits; AO Failed to Prove Loan Existence.

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....Penalty u/s 271E - repayment of deposits in cash made by the assessee to her related persons - default u/s 269T - the burden entirely lay upon AO first to establish that there existed a loan or advance and the contentious payment in repayment of such loan - No penalty.....