XLLENT MARINE LINE PRIVATE LIMITED,CHENNAI vs. INCOME TAX OFFICER CHE-C-(253)(1), CHENNAI
What were the facts?
The assessee company settled a director's account through journal entries and set-offs, which the Assessing Officer (AO) treated as a repayment of a loan or deposit under Section 269T, leading to a penalty under Section 271E. The Commissioner of Income Tax (Appeals) confirmed this penalty.
What did the Tribunal hold?
The Tribunal held that the director's account was a running current account and not a loan or deposit. Settling such an account through journal entries does not amount to repayment under Section 269T, especially when no cash movement is involved.
What were the issues?
Whether journal entries for mutual adjustment of accounts constitute 'repayment' under Section 269T, and if a penalty under Section 271E is leviable in such circumstances.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI
Before: HONOURABLE SHRI S.S. VISWANETHRA RAVI & SHRI GAGAN GOYAL
PER GAGAN GOYAL, AM: This is an appeal preferred by the assessee against the order of Ld.
Commissioner of Income Tax (A) / NFAC, (hereinafter referred as the ‘Ld. CIT(A)’), Delhi dated 21.01.2026, for the Assessment Year (hereinafter referred as the ‘AY’) 2023-24. GROUDS OF APPEAL (a)
The Appellant respectfully submits the following grounds of appeal against the
The order continues below.
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More judgments on Section 269T
- Mr. Ujjwal, Bengaluru vs ITO, Ward-5(2)(1), BangaloreITA 809/BANG/2026[2014-15]Status: Disposed29 Sept 2026AY 2014-15
- Assistant Commissioner of Income Tax… vs A.K.Thangamaligai, Manapparai, TrichyITA 2868/CHNY/2026[2021-22]Status: Disposed25 Sept 2026AY 2021-22
- Nisa Chits India Pvt. Ltd., Coimbatore vs ITO, Corporate Ward-1, CoimbatoreITA 2868/CHNY/2025[2017-18]Status: Disposed25 Sept 2026AY 2017-18
- Samriddhi Petro Products Private Limited… vs ACIT, Circle-3(1), HyderabadITA 101/HYD/2026[2014-15]Status: Disposed23 Sept 2026AY 2014-15
- Amba Properties Private Limited, Delhi vs Deputy Commissioner of Income Tax, Circle…ITA 3513/DEL/2026[2018-19]Status: Disposed18 Sept 2026AY 2018-19
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