In the result, the appeal filed by the assessee is allowed
Bench: Sri Sanjay Garg & Dr. Manish Borad
Section 269T of the Act and therefore, initiated penalty proceedings 271E of the Act. Page 3 of 8 I.T.A. No.: 594/KOL/2023 Assessment Year: 2015-16 M/s. Shree Shankar Service Station. 5. During the course of penalty proceedings when the assessee was confronted with the alleged repayment of unsecured loan in cash, it was stated by the assessee that