2025 (11) TMI 1757

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....it against the order dated 10.02.2022 passed u/s 271E of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') by the National Faceless Assessment Centre, Delhi, New Delhi (hereinafter referred to as the Ld. AO). 2. On hearing both the sides, we find that primarily on behalf of the assessee the penalty order has been challenged on legal as well as on factual grounds and, for convenience, the grounds are reproduced below:- "1. On the facts and circumstances of the case, the learned CIT(A) NFAC erred on facts and in law in confirming the levy of the penalty of Rs. 30,00,000 under section 271E of the Income-tax Act, 1961 ("the Act"). 2. That the learned CIT(A) NFAC erred on facts and in law in not deleting the pe....

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....onetization. It is to be noted here that the assessee was a businessman and regular filer of income tax return. Although demonetization of currency was declared, the assessee was having enough time from 08/11/2016 to 31/12/2016 for depositing the old currency in his bank account. The assessee ought to have deposited cash from sale of footwear in his bank account and then repay the loan amount to his creditors. However without any reasonable cause, the assessee repaid loan amount of Rs. 30,00,000/- in cash to his creditors thereby violating provisions of section 269T of the Act. Thus the appellant repaid the amounts in cash without any reasonable cause. Therefore I do not find any excuse to take a divergent view from the view of the....