Commissioner of Income Tax v. Triumph International Finance (I) Ltd.

345 ITR 270High Court2012#933 most cited

What is Commissioner of Income Tax v. Triumph International Finance (I) Ltd. authority for?

Transactions involving the receipt or repayment of loans or deposits solely through journal entries, without actual cash movement, contravene Sections 269SS and 269T. However, penalties under Sections 271D or 271E for such contraventions are not imposable if the assessee demonstrates a reasonable cause under Section 273B, particularly when no cash has passed between parties.

114

judgments rely on this decision, according to BharatTax’s citation analysis of 367,735 Indian tax judgments — from 2015 to 2026.

Also referred to as

Commissioner of Income Tax v. Triumph International Finance · penalty under Section 271D · penalty under Section 271E · Section 269SS · Section 269T · journal entries · loans and deposits · reasonable cause · Section 273B · deletion of penalty

Also reported as

22 Taxmann.com 138208 Taxmann 299

Sections most often in play

Section 269SSSection 271DSection 143(3)Section 271ESection 273BSection 269TSection 10(26AAA)Section 68

Issues it is cited on

penalty under section 271epenalty under section 271dsection 269tsection 269ssection 271esection 273section 269sssection 271dsection 269deletion of penaltysection 249(3)section 273b

Judgments citing Commissioner of Income Tax v. Triumph International Finance (I) Ltd.

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

ITA 1743/KOL/2025[2021-2022]Status: DisposedITAT Kolkata13 Jan 2026AY 2021-2022

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 10Section 143(2)Section 250

…held where transactions are effected only through books adjustment and no cash passes between the parties, section 269SS of the Act is not attracted. Similarly, The Hon’ble Bombay High Court in the case of Triumph International Finance (I) Ltd. Vs ACIT (2012) 345 ITR 270 (Bom) that no penalty is to be imposed in case of journal entries. Therefore, we are inclined to set aside the order of CIT(A) and direct the AO to delete the penalty. 8 ITA Nos.1739-1743/Kol/2025 Roshan Agarwal 19. In result, all the four appeals in ITA Nos. 1739, 1740, 1741 & 1742/Kol/ 2025 are allowed and ITA No. 1743/Kol/2025 is allowed for…

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

ITA 1742/KOL/2025[2017-2018]Status: DisposedITAT Kolkata13 Jan 2026AY 2017-2018

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 10Section 143(2)Section 250

…held where transactions are effected only through books adjustment and no cash passes between the parties, section 269SS of the Act is not attracted. Similarly, The Hon’ble Bombay High Court in the case of Triumph International Finance (I) Ltd. Vs ACIT (2012) 345 ITR 270 (Bom) that no penalty is to be imposed in case of journal entries. Therefore, we are inclined to set aside the order of CIT(A) and direct the AO to delete the penalty. 8 ITA Nos.1739-1743/Kol/2025 Roshan Agarwal 19. In result, all the four appeals in ITA Nos. 1739, 1740, 1741 & 1742/Kol/ 2025 are allowed and ITA No. 1743/Kol/2025 is allowed for…

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

ITA 1741/KOL/2025[2015-2016]Status: DisposedITAT Kolkata13 Jan 2026AY 2015-2016

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 10Section 143(2)Section 250

…held where transactions are effected only through books adjustment and no cash passes between the parties, section 269SS of the Act is not attracted. Similarly, The Hon’ble Bombay High Court in the case of Triumph International Finance (I) Ltd. Vs ACIT (2012) 345 ITR 270 (Bom) that no penalty is to be imposed in case of journal entries. Therefore, we are inclined to set aside the order of CIT(A) and direct the AO to delete the penalty. 8 ITA Nos.1739-1743/Kol/2025 Roshan Agarwal 19. In result, all the four appeals in ITA Nos. 1739, 1740, 1741 & 1742/Kol/ 2025 are allowed and ITA No. 1743/Kol/2025 is allowed for…

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

ITA 1740/KOL/2025[2014-2015]Status: DisposedITAT Kolkata13 Jan 2026AY 2014-2015

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 10Section 143(2)Section 250

…held where transactions are effected only through books adjustment and no cash passes between the parties, section 269SS of the Act is not attracted. Similarly, The Hon’ble Bombay High Court in the case of Triumph International Finance (I) Ltd. Vs ACIT (2012) 345 ITR 270 (Bom) that no penalty is to be imposed in case of journal entries. Therefore, we are inclined to set aside the order of CIT(A) and direct the AO to delete the penalty. 8 ITA Nos.1739-1743/Kol/2025 Roshan Agarwal 19. In result, all the four appeals in ITA Nos. 1739, 1740, 1741 & 1742/Kol/ 2025 are allowed and ITA No. 1743/Kol/2025 is allowed for…

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

ITA 1739/KOL/2025[2013-2014]Status: DisposedITAT Kolkata13 Jan 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 10Section 143(2)Section 250

…held where transactions are effected only through books adjustment and no cash passes between the parties, section 269SS of the Act is not attracted. Similarly, The Hon’ble Bombay High Court in the case of Triumph International Finance (I) Ltd. Vs ACIT (2012) 345 ITR 270 (Bom) that no penalty is to be imposed in case of journal entries. Therefore, we are inclined to set aside the order of CIT(A) and direct the AO to delete the penalty. 8 ITA Nos.1739-1743/Kol/2025 Roshan Agarwal 19. In result, all the four appeals in ITA Nos. 1739, 1740, 1741 & 1742/Kol/ 2025 are allowed and ITA No. 1743/Kol/2025 is allowed for…

Yuksom Breweries Ltd., Sikim vs. Addl./Joint CIT, Range - 2, Siliguri

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1921/KOL/2024[2018-2019]Status: DisposedITAT Kolkata16 Jul 2025AY 2018-2019

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 143(3)Section 250Section 269TSection 271ESection 273BSection 274

…ctive party’s account. These were pointed out by the Auditor as violation of section 269T of the Act. Reliance has been placed on the decision of Hon'ble Bombay High Court in the case of [2012] 22 taxmann.com 138 (Bombay)/[2012] 208 Taxman 299 (Bombay)/[2012] 345 ITR 270 (Bombay)/[2012] 251 CTR 253 (Bombay)[12-06-2012] wherein the Hon'ble Court has held as under: “The basic question to be considered is, whether repayment of loan of Rs. 4,28,99,325 by making journal entries in the books of account maintained by the assessee is in contravention of section 269T, and, if so, for failure to comply with the provisions…

Jeevangani Films, Mumbai vs. Joint Commissioner of Income Tax, Range -16(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 382/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Shri. Omkareshwar Chidarajeevangani Films Vs Joint Commissioner Of Income Tax, Plot No.53/1, Media Infotek Range-16(1), Mumbai Park Road No.7, Opp. Ackruti Trade Centre, Midc, Marol, Andheir (E), Mumbai -400 093 Pan : Aajfj9661M Appellant Respondent

For Appellant: Shri Rakesh JoshiFor Respondent: Ms. Kavitha Kaushik,(SR DR)
Section 139Section 143(3)Section 250Section 269SSection 271DSection 271E

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI. OMKARESHWAR CHIDARA, ACCOUNTANT MEMBER Jeevangani Films vs Joint Commissioner of Income Tax, Plot No.53/1, Media Infotek Range-16(1), Mumbai Park Road No.7, Opp. Ackruti Trade Centre, MIDC, Marol, Andheir (E), Mumbai -400 093 PAN : AAJFJ9661M APPELLANT RESPONDENT Assessee by : Shri Rakesh Joshi Respondent by : Ms. Kavitha Kaushik,(SR DR) Date of hearing : 03/03/2025 Date of pronouncement : 06/03/2025 O R D E R PER ANIKESH BANERJEE, J.M: The instant appeal of the assessee was filed against th…

Nilons Enterprises Pvt.Ltd, Pune vs. Ward 2(4), Pune

In the result, appeal of the Assessee is allowed

ITA 1600/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai, Addl. CIT-DR
Section 143(3)Section 269TSection 271E

…in holding that receipt of any advance/loan by way of journal entries is in breach of Section 269SS of the Act as the decision of this Court in CIT v. Triumph International 14 ITA.No.1600/PUN./2024 Finance (I) Ltd. [2012] 22 taxmann.com 138/208 Taxman 299/345 ITR 270 (Bom.) is binding upon it. However, the Revenue's grievance is with the impugned order dated 27th June, 2014 of the Tribunal further holding no penalty under Section 271D of the Act is imposable in view of Section 273B of the Act in the present facts. This is so as the Tribunal holds that the failure to comply with Section 269SS of the Act was…

ACIT -14 (2), Mumbai vs. Redwood I.T. Services P.Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 1643/MUM/2021[2013-14]Status: DisposedITAT Mumbai20 Sept 2023AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Narender Kumar Choudhry (Jm)

Section 269SSection 269TSection 271DSection 271ESection 273B

…IN THE INCOME TAX APPELLATE TRIBUNAL Mumbai “H” Bench, Mumbai. Before Shri B.R. Baskaran (AM) & Shri Narender Kumar Choudhry (JM) I.T.A. No. 1643/Mum/2021 (A.Y. 2013-14) Vs. M/s. Redwood I.T. ACIT, Circle-14(1)(2) Room No. 455 Services Pvt. Ltd. 4th Floor D-211, Ghatkopar Aayakar Bhavan Industrial Estate M.K. Road Behind R-City Mall Churchgate Off. LBS Marg, Mumbai-400 020. Ghatkopar West Mumbai-400 086. PAN : AADCR7296K (Appellant) (Respondent) Assessee by Shri Vijay Mehta Department by Smt. Madhumalti Ghosh Date of Hearing 25.07.2023 Date of Pronouncement 20.09.2023 O R D E R Per B.R.Baskaran (AM) :- T…

DCIT-15(3)(1), Mumbai vs. M/S. Translands Infrastructure Developers P Ltd, Vashi

In the result, the appeal of the revenue is dismissed

ITA 1913/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Sept 2023AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailthe Dy. Commissioner Of Vs. M/S Translands Income-Tax, 15(3)(1), Infrastructure Developers Mumbai P. Ltd. Jn-3-14-5, Asshirwad Chs, Sector-09, Vashi, Navi Mumbai-400 703 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadct 0036 B Appellant .. Respondent

For Appellant: Ms. Rupa NandaFor Respondent: Shri P. D. Chougule, Sr. AR
Section 143(3)Section 147Section 269SSection 271DSection 273BSection 3Section 68

…of accounts of assessee by crediting the account of IL & FS. The facts of this case is similar to facts of appellant where too the transaction was made vide journal entry. d) The Hon'ble Bombay High Court in CIT vs Triumph International finance (India) Ltd in 345 ITR 270 held that "loan taken by way of journal entry would violate the provisions of section 269SS warranting levy of penalty u/s. 2710 of Act". 7 DCIT vs. M/s Translands Infrastructure Developers P Ltd However, it was further held that reasonable cause given by assessee should be considered. Hon'ble High Court took note of the fact that Revenue has no…

M/S Prashanth Fertility Research Centre Pvt Ltd, Chennai vs. JCIT, Chennai

In the result, the appeal filed by the assessee is allowed

ITA 389/CHNY/2022[2018-19]Status: DisposedITAT Chennai17 May 2023AY 2018-19

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.389/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Prashanth Fertility Research Vs. The Joint Commissioner Of Centre Pvt. Ltd., Door No. 76 & 77, Income Tax, Harrington Road, Chennai 600 031. Corporate Range 5, Chennai 600 034. [Pan:Aaccp2513J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 03.05.2023 घोषणा की तारीख /Date Of Pronouncement : 17.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 22.03.2022 Relevant To The Assessment Year 2018-19 Passed Under Section 271Da Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 269SSection 271D

…chnical or venial beach of the provisions of the Act or when there is breach flows from the bona fide belief that the offender is not liable to act in the manner prescribed by the statute. The Hon'ble Bombay High Court in CIT vs Triumph International Finance (345 ITR 270). "It is not established that there is a deliberate and intentional violation of the provisions by the assessee in order to hide any income or to evade any payment of tax. Even if the assessee has technically contravened provisions of section 269ST, in absence of finding to effect that repayment of loan/ deposit was not a bona fide transaction an…

Mita Holdings Pvt. Ltd., Mumbai vs. Addll. CIT - CC - 3, Mumbai

In the result, appeal of the assessee is allowed

ITA 1817/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Apr 2023AY 2014-15
Section 269TSection 271E

…Tracon P. Ltd., M/s Kartik Credit P. Ltd. and M/s. Navodaya Exim P. Ltd”. 5 M/s. Mita Holdings Pvt. Ltd. 6. Ld. CIT (A) also referred to the decision of the Hon’ble Jurisdictional High Court in the case of Triumph International Finance (I) Ltd., reported in 345 ITR 270 (Bombay High Court), wherein the Hon’ble High Court has held that penalty u/s.271E is not leviable in a case where the loans are squared up by way of book adjustments or by way of journal entries, provided they are bonafide commercial transactions. Thereafter, the ld. CIT(A) carried out his own enquiry and verification to ascertain as to whether…

M/S Sanjeev Chirania HUF, Mumbai vs. Income Tax Officer, Ward-28(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 251/MUM/2023[2015-16]Status: DisposedITAT Mumbai31 Mar 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2015-16 M/S Sanjeev Chirania Huf, Ito-28(3)(1), 301, Sona Chambers, 507/509 Tower No. 6, Vashi Railway Vs. Jss Road, Chira Bazar, Station Commercial Marine Lines – East, Complex, Vashi, Mumbai-400 002. Navi Mumbai-400703 Pan No. Aarhs 4527 D Appellant Respondent Assessee By : Ms. Ritu Kamalkishor, Ar Revenue By : Mr. Milind S. Chavan, Cit-Dr : Date Of Hearing 23/03/2023 : Date Of Pronouncement 31/03/2023 Order

For Appellant: Ms. Ritu Kamalkishor, ARFor Respondent: Mr. Milind S. Chavan, CIT-DR
Section 147Section 148Section 271F

…91 to 902/Bang/2017) No: 891 to 902/Bang/2017) e. Hon'ble High Court of Bombay in CIT Vs. Triumph e. Hon'ble High Court of Bombay in CIT Vs. Triumph e. Hon'ble High Court of Bombay in CIT Vs. Triumph International Finance L International Finance Limited[2012] 345 ITR 270.” .” 4. On contrary, the Ld. Departmental Representative (DR) On contrary, the Ld. Departmental Representative (DR) On contrary, the Ld. Departmental Representative (DR) supported the order of the lower authorities and submitted that for supported the order of the lower authorities and submitted that for supported the order of the lower authoriti…

Deputy Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Mahavir Build Estate Pvt Ltd, Mumbai

In the result, appeal preferred by the Revenue is dismissed

ITA 1405/MUM/2022[2009-2010]Status: DisposedITAT Mumbai20 Dec 2022AY 2009-2010
For Appellant: Shri Gunajjan KakkadFor Respondent: Shri Nishant Somaiya
Section 132Section 143(3)Section 147Section 250Section 269SSection 271DSection 273B

…ries would be hit by Section 269SS of the Act, nevertheless, where such ITA. No. 1405/Mum/2022 Assessment Year: 2009-10 transactions were made by an assessee prior to the decision of the Hon'ble Bombay High Court in the case of Triumph International Finance (345 ITR 270), the provisions of Section 271D of the Act would not be attracted, as the assessee shall be deemed to have had reasonable cause to receive the deposits/loans through journal entries, which would also be a reasonable cause under Section 273B of the Act for non- imposition of penalty u/s.271D of the Act. The Special Leave Petitions against the afo…

Deputy Commissioner of Income Tax.CC-7(3)., Mumbai vs. M/S Macrotech Developers Ltd(Successsor to Palava Dwellers Pvt Ltd), Mumbai

ITA 1348/MUM/2022[2016-2017]Status: DisposedITAT Mumbai29 Sept 2022AY 2016-2017
Section 115JSection 143(3)Section 144C(13)Section 269SSection 271DSection 273B

…s nowhere mentioned that this principle would apply only in case of transaction with one only. 8. We find that the ld. CIT(A) relied on the judgement of Hon’ble Jurisdictional High Court in the case of CIT vs Triumph International (I) Finance Ltd reported in 345 ITR 270 (Bom) as under:- 19. In the present case, it is not in dispute that the assessee has repaid loan/deposit by debiting the account through journal entries. The question is, whether such repayment of loan/deposit is in contravention of the modes of repayment set out in Section 269T ? The argument advanced by the counsel for the assessee that the bon…

Deputy Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd (Successor to Shreenivas Cotton Mills Ltd), Mumbai

ITA 1347/MUM/2022[2014-15]Status: DisposedITAT Mumbai29 Sept 2022AY 2014-15
Section 115JSection 143(3)Section 144C(13)Section 269SSection 271DSection 273B

…s nowhere mentioned that this principle would apply only in case of transaction with one only. 8. We find that the ld. CIT(A) relied on the judgement of Hon’ble Jurisdictional High Court in the case of CIT vs Triumph International (I) Finance Ltd reported in 345 ITR 270 (Bom) as under:- 19. In the present case, it is not in dispute that the assessee has repaid loan/deposit by debiting the account through journal entries. The question is, whether such repayment of loan/deposit is in contravention of the modes of repayment set out in Section 269T ? The argument advanced by the counsel for the assessee that the bon…

Deputy Commissioner of Income Tax CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd.(Successor to M/S Lodha Developer Pvt Ltd), Mumbai

ITA 1291/MUM/2022[2015-16]Status: DisposedITAT Mumbai29 Sept 2022AY 2015-16
Section 115JSection 143(3)Section 144C(13)Section 269SSection 271DSection 273B

…s nowhere mentioned that this principle would apply only in case of transaction with one only. 8. We find that the ld. CIT(A) relied on the judgement of Hon’ble Jurisdictional High Court in the case of CIT vs Triumph International (I) Finance Ltd reported in 345 ITR 270 (Bom) as under:- 19. In the present case, it is not in dispute that the assessee has repaid loan/deposit by debiting the account through journal entries. The question is, whether such repayment of loan/deposit is in contravention of the modes of repayment set out in Section 269T ? The argument advanced by the counsel for the assessee that the bon…

Deputy Commissioner of Income Tax CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd(Earlier Known As M/S Lodha Developers Pvt Ltd), Mumbai

ITA 1290/MUM/2022[2015-2016]Status: DisposedITAT Mumbai29 Sept 2022AY 2015-2016
Section 115JSection 143(3)Section 144C(13)Section 269SSection 271DSection 273B

…s nowhere mentioned that this principle would apply only in case of transaction with one only. 8. We find that the ld. CIT(A) relied on the judgement of Hon’ble Jurisdictional High Court in the case of CIT vs Triumph International (I) Finance Ltd reported in 345 ITR 270 (Bom) as under:- 19. In the present case, it is not in dispute that the assessee has repaid loan/deposit by debiting the account through journal entries. The question is, whether such repayment of loan/deposit is in contravention of the modes of repayment set out in Section 269T ? The argument advanced by the counsel for the assessee that the bon…

DCIT Cen Cir 7(3), Mumbai vs. Kesarinandan Township P.Ltd, Mumbai

In the result, all the captioned appeals preferred by revenue stands dismissed and the CO of the assessee also stands dismissed

ITA 2581/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2022AY 2010-11
For Appellant: Shri Vijay MehtaFor Respondent: Shri Chhotarary (Special Counsel)
Section 269SSection 269TSection 271DSection 271E

…i.e. the acceptance/repayment of loan/advance/deposit is in violation of modes specified in Section 269SS & Section 269T of the Act. We find that the said issue is no longer res-integra as held by the Hon’ble Bombay High Court in CIT Vs. Triump International (345 ITR 270) wherein their Lordships held C.O. 275 & 276/Mum/2018 A.Y. 2010-11 & 2012-13 Kesarinanadan Township. that the receipt of any advance/loan by way of journal entries is in breach of Section 269SS of the Act. In such a scenario, the next question is whether penalty is leviable for breach of Section 269SS/269T of the Act. In the present cases, the A…

DCIT Cen Cir 7(3), Mumbai vs. Kesarinandan Township P.Ltd, Mumbai

In the result, all the captioned appeals preferred by revenue stands dismissed and the CO of the assessee also stands dismissed

ITA 2580/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2022AY 2010-11
For Appellant: Shri Vijay MehtaFor Respondent: Shri Chhotarary (Special Counsel)
Section 269SSection 269TSection 271DSection 271E

…i.e. the acceptance/repayment of loan/advance/deposit is in violation of modes specified in Section 269SS & Section 269T of the Act. We find that the said issue is no longer res-integra as held by the Hon’ble Bombay High Court in CIT Vs. Triump International (345 ITR 270) wherein their Lordships held C.O. 275 & 276/Mum/2018 A.Y. 2010-11 & 2012-13 Kesarinanadan Township. that the receipt of any advance/loan by way of journal entries is in breach of Section 269SS of the Act. In such a scenario, the next question is whether penalty is leviable for breach of Section 269SS/269T of the Act. In the present cases, the A…