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2002 (7) TMI 749

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..... ingh, A.M. - The above appeal of the Revenue and Cross Objection of the assessee are being disposed of by a common order of date for the sake of convenience as they arise from the order of the ld. CIT(A)-II, Kanpur, dated 12-9-1994. 2. On behalf of the Revenue, Shri Prasenjit Singh, ld. Sr. DR attended whereas Shri G.P. Sinha, A.R. attended on behalf of the assessee and made their respective subm .....

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..... s of section 269SS/269T and imposed the penalty under section 271D at Rs. 7,76,691 and Rs. 7,91,204 under section 269T. On appeal, the ld. CIT(A) deleted these penalties by combined order dated 12-9-1994 for the assessment year 1992-93 holding that the transactions in question were transfer entries only in the books of account and there was no introduction of cash or money in any form, therefore, .....

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..... e decision of the Cochin Bench reported in Muthoot M. George Bankers v. Asstt. CIT [1993] 46 ITD 10 and that of Ahmedabad Bench reported in Bombay Conductors & Electricals Ltd. v. Dy. CIT [1997] 90 Taxman 138, the position emerges that for violation of section 269SS. It necessarily requires involvement of transfer of money which was not in the assessee's case. There being no deposit as per the mod .....

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