In the result, the appeal is partly allowed
Bench: Shri N.R.S. Ganesan & Shri Sanjay Arora
68 (see: Vijay K. Talwar v. CIT [2011] 330 ITR 1 (SC)), i.e., irrespective of whether the receipt back is in cash – again liable for penalty u/s. 271E, or not, i.e., through the banking channel; the transaction being regarded as not genuine. Why, one may ask, would any person give ‘loan’ to such a person, i.e., knowing fully well that