Penalty u/s 271-D Overturned: Crop Sale Transactions Not Considered Loan or Deposit, Section 269SS Inapplicable.

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....Penalty u/s 271-D - default u/s 269SS - transactions between the assessee and the Commission Agent who sale agriculture crops - receipt by the assessee against the sale of the crops was neither the loan nor the deposit, therefore the provisions of Section 269SS were not applicable and as such penalty levied u/s 271D is not sustainable....