Shri Balbir Singh M/S Jaideep Gift Centre Taptej Singh Market, Moga vs. Additional Commissioner of Income Tax Moga Range Moga, Moga
In the result, both the appeals filed by the assessee are allowed for
ITA 746/ASR/2017[2011-12]Status: DisposedITAT Amritsar18 Jul 2023AY 2011-12
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
For Appellant: Sh. P. N. Arora, AdvFor Respondent: Sh. Radhey Shyam Jaiswal, Sr. DR
Section 143(3)Section 269SSection 269TSection 27Section 271D
…mon sense and reason if it were so. It was also stated that "it is impossible to know all the statutory law, and not very possible to know all the common law”. Further, the Hon’ble Madras Court in the case of in the case of CIT vs. KPVS Mohammad Rowther & Co. 232 ITR 176 (Mad) held that ignorance of law can be a reasonable cause for the failure and deletion of penalty was justified. Where the Ld. AO during Assessment proceedings already made additions of such Loan (as held by AO) as deemed dividend u/s 2(22e), it is not justified to invoke provisions of section 269SS and 269TT of the Act. The assessee is an ordin…