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TMI Blog2019 (5) TMI 1966X X X X Extracts X X X X X X X X Extracts X X X X ..... ification has been given by the assessee for borrowals at a higher rate and corresponding lending at a lower rate. Clearly the excess interest paid to the relatives qua the loans and advances do not appear to carry attributes of commercial expediency. Therefore, the Revenue authorities were justified in making disallowance of excess interest expenditure. We thus find no infirmity in the order of the CIT(A) and hence, decline to interfere. Penalty u/s 271D - contravention of provisions of section 269SS - matter of accepting unsecured deposit in cash from Wife of the Appellant - HELD THAT:- We find that assessee has supported the receipt of cash from wife by way of documentary evidences and bonafides of action. The transaction has been d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 13-14, wherein the following grounds have been raised: The ld. CIT(A)-I, Rajkot has erred in law and on facts for dismissing the appeal for ld. Assessing Officer wrongly disallowed interest expenditure Rs.77,907/- to following relatives on the alleged ground of estimatinfg reasonable rate of interest @ 12% in contrast to actual rate of interest paid @ 15% without finding the reasons for unreasonableness of the interest rate at prevailing market rate and thereby, wrongly disallowed 3% higher interest payment. (i) Smt. Kaushalyadevi R. Sahu Mother of the Appellant Rs.68,921 (ii) Smt.Komal Naresh Sahu -Wife of the Appellant Rs. 8,986 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsecured deposit Rs.50000 in cash from, Smt.Komal N. Sahu, Wife of the Appellant. 6. With the assistance of Ld.AR for the assessee and Ld.DR for the revenue, we note that the assessee, an individual, was imposed penalty under s.271D of the Act for violation of provisions of section 269SS of the Act for cash deposit of Rs.50,000/- received on 30/04/2012 from his wife Smt.Komal N.Sahu. 7. From a bare reading of the order of the CIT(A), we find that assessee has supported the receipt of cash from wife by way of documentary evidences and bonafides of action. The transaction has been done with spouse and claimed that the assessee was under bonafide belief that transaction with intimate person could not attract mischief of provisions of act ..... X X X X Extracts X X X X X X X X Extracts X X X X
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