2025 (2) TMI 87

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....(hereinafter, the 'Act') whereas the appeal ITA No.1309/Del/2018 is in respect of penalty levied under section 271E of the Act. These penalty cases are in challenge, by the assessee, before us. 3. The relevant facts giving rise to these appeals are that the assessee had entered into an agreement to sale of a plot to Mr. Ashwani Kumar, a Government Employee. The Central Bureau of Investigation (hereinafter, the 'CBI') had searched the residential and office premises of Mr. Ashwani Kumar, wherein they found one agreement to sale for acquiring a plot in the name of Mrs. Meenakshi Mansotra, wife of Mr. Ashwani Kumar. As per this agreement to sale, Mr.Ashwani Kumar had paid Rs. 30,00,000/- on-money in cash to the assessee. Consequent to the s....

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.... Tax, Panipat Range (hereinafter, the 'JCIT'), being not convinced with the reasonable cause/ circumstances/facts mentioned above, levied penalty for accepting cash loans aggregating to Rs. 17,00,000/- in violation of the provisions of section 269SS of the Act. 3.2 Later on, the cash loan Rs. 3,50,000/- taken from Mr. Naveen Kaushik was returned back in cash in violation to the provision of Section 269T of the Act. Therefore, the JCIT, Range Panipat levied penalty of Rs. 3,50,000/- under section 271E of the Act. 3.3 Aggrieved, the assessee filed appeals but failed to succeed. 4. Before us, the Ld. Authorized Representative (hereinafter, the 'AR') submitted that the assessee had a reasonable cause for accepting the cash loan and rep....