Penalty Under Section 271D Quashed as Time Limit Expired Despite TOLA Extension for Cash Loans Violating Section 269SS

The ITAT quashed penalty proceedings under section 271D imposed on the assessee for accepting cash loans of Rs. 61,50,000/- in violation of section 269SS. The Tribunal held that the show cause notice dated 30.03.2021 required penalty order completion by 30.09.2021, which fell outside the Taxation and Other Laws Act (TOLA) period (20.03.2020 to 31.03.2021). Consequently, the CBDT notification dated 17.09.2021 did not extend the due date for passing the penalty order in this case. Following precedents in Mahesh Wood Products Pvt. Ltd. and Shri Subramaniam Thanu, the ITAT upheld the CIT(A)'s decision to quash the penalty order due to limitation issues. .....

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