2025 (4) TMI 2151

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....ITBA/NFAC/S/250/2023-24/1057061187(1) dated 14.10.2023 against the order of assessment passed u/s 271E of the Income-tax Act, 1961 (hereinafter referred to as "the Act") dated 27.06.2017 by Add CIT, Range-3, New Delhi (hereinafter referred to as "ld. AO"). 2. The only effective issue to be decided in this appeal is as to whether the provisions of Section 269T of the Act and consequentially levy of penalty u/s 271E of the Act could be made applicable in the facts and circumstances of the instant case. 3. We have heard the rival submissions and perused the material available on record. The assessee is engaged in the business of trading and printing of Tin Sheets used for manufacturing of Tin containers, containing and printing of Tin Sh....

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..... Asian Consolidated Industries Ltd Rs. 6,10,000/- M/s. Rajasthan Breweries Ltd Rs. 50,000/- Total Rs. 41,55,260/- 6. The assessee submitted all the three entities are sister concerns of the assessee and submitted their entire ledger account as appearing in its books to establish the nature of transactions. From the ledger account of M/s. Asian Closure Ltd enclosed in pages 55 to 57 of the Paper Book, we find that assessee had made certain purchases from the said party and had merely made payments to them against the bills raised. The assessee is having a running account with the said party. We hold that it is not a case of repayment of any loan to the said party. 7. With regard to M/s. Asian Consolidated Industries Ltd....