TaxTMI 
TaxTMI 
2023 (9) TMI 440
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....gainst the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short "Ld. CIT(A)"), National Faceless Appeal Centre (in short "NFAC"), Delhi on 26.04.2023 & 27.03.2023 for A.Ys. 2013-14 & 2016-17. 2. As all the grounds of appeal are identical in both the appeals except the figure so we are only raised the grounds of ITA No. 338/Ahd/2023 for A.Y. 2013-14 as under: "1. The order pas....
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....assessee has accepted loan of Rs. 1,70,000/- during the relevant period from The Berna Gamni Seva Sahkari Mandali Ltd. The Assessing Officer based on the said information issue show-cause notice dated 13.05.2019 for levy of penalty under Section 271D for contravention of Section 269SS of the Act. The assessee filed reply dated 20.05.2019 thereby stating that acceptance of loan of Rs. 1,70,000/- fr....
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.... CIT(A). The CIT(A) dismiss the appeal of the assessee. 6. The Ld. A.R. submitted that since the assessee is an agriculturist there was no regular assessment done by the authorities. Therefore, the question of contravention of Section 269SS of the Act does not sustain. The Ld. A.R. further submitted that all the documentary evidence that the said loan was taken through banking channel and the res....
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....in assessee's case as the assessee is an agriculturist. Further, the Assessing Officer as well as the CIT(A) has not doubted the bank statement of the assessee wherein the amount of Rs. 2,30,000/- which was transferred from The Berna Gamni Seva Sahkari Mandali Ltd. was shown dated 24.05.2012. The transactions as well as the ledger alongwith the certificate issued by The Berna Gamni Seva Sahkari Ma....