2024 (2) TMI 789

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.... 1961 (the "Act") pertaining to Assessment Year ("AY") 2013-14. 2. Briefly stated, the assessee e-filed his return on 30.09.2013 declaring income of Rs. 4,91,490/- for AY 2013-14. The Ld. ITO Ward-3(5) Hapur ("AO") completed the assessment on 15.03.2016 on total income of Rs. 56,48,590/- under section 143(3) of the Act wherein the Ld. AO initiated penalty proceedings under section 271D of the Act for accepting cash loan of Rs. 2 lakh in aggregate without any reasonable cause in contravention to section 269SS. He referred the matter to the Ld. Addl. CIT Bulandsahar who served show cause notice upon the assessee to which he submitted reply on 18.05.2016. Rejecting the explanation offered by the assessee, the Ld. Addl. CIT Bulandsahar impos....

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....Act because the Assessee had not taken any loan/deposit exceeding Rs. 20,000/- at a time from M/S A. K. Trading Co. Confirmed copy of A/c of M/S Pramod Trading Co. in the books of M/S A.K. Trading Co. is placed ot page 5. It is not in dispute that M/S Pramod Trading Co. is the sole proprietary concern of Sh. Pramod kumar as is evident from ITR, computation of total income and audited balance sheet and P & L A/c for the year under consideration, copies placed ot pages 6-14. Similarly, Sh. Akhilesh Garg is the sole proprietor of M/S A.K. Trading Co and is separately assessed to tax at Hapur having PAN No. AGNPG76008 as is evident from ITR, computation of total income and balance sheet and P & LA/c for the year under consideration, copies plac....