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2002 (7) TMI 749

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..... ondent. ORDER Mohan Singh, 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 assess .....

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..... e penalty for violation of provisions 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 ca .....

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..... d 28-6-1982 and 387 dated 6-7-1984 and the 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 asses .....

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