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Penalty u/s 271D Not Upheld for Cash Loan Between Director and Father; No Tax Evasion Proven.

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....Penalty Levy u/s 271D - assessee has received unsecured loan in cash in contravention of the provisions contained u/s 269SS - When source of the cash receipt is not in dispute and transaction between the Director of the company and his father has also not been disputed by Revenue and it has not prejudiced the interest of the Revenue in any manner as no tax avoidance and tax evasion has been alleged or proved - AT....