2016 (12) TMI 619

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..... rpose of the assessee's business. It is further found that all the persons who had kept their amounts were agriculturists; that such persons had the means to deposit the amounts; that the deposits were treated as genuine and that the assessment of the amounts were accepted and explained. The CIT (Appeals) and the Tribunal also accepted the reasons for the appellant's accepting the same. They found .....

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..... bstantial questions of law arise for consideration: (i) Whether, on the facts and circumstances of the case and in law, the ITAT has erred in deleting the penalty imposed under Section 271D of the Act, by observing that the amounts kept by agriculturist with commission agents were outside the purview of provisions of Section 269SS of the Act, failing to appreciate that the respondent had acce .....

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..... Haryana High Court in the case of Charan Dass Ashok Kumar Vs. CIT, 365 ITR 367 wherein it was held by the Hon'ble Court, under similar circumstances that where respondent failed to establish that there was reasonable cause in accepting any loan/deposit in case, the action of the AO imposing penalty under Section 271D was justified and the ratio of judgment of the Hon'ble Punjab and Harya .....

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