2017 (2) TMI 1507

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..... ted decisions holding that Section 269SS is not attracted in transactions between a partnership firm and its partner not partaking the character of a loan and deposit in general law as held in another co-ordinate bench decision in ITO vs. Bharat kumar Dayaram Patel[ 2010 (10) TMI 1228 - ITAT AHMEDABAD] . We accordingly draw support therefrom and uphold the CIT(A) s order under challenge deleting S .....

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..... ership firms M/s. Concept Transmission and Shanti Trading Co. in the relevant previous year. The Assessing Officer penalized him u/s.271D of the Act by treating the above loan transaction to be violating Section 269SS of the Act. The CIT(A) quotes various decisions including Shrepak Enterprises vs. DCIT 60 TTJ 199 (Ahd) as well as hon ble Rajasthan high court s judgment in CIT vs. Lokhpat Film E .....

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