Equivalent consider has been taken in CITvs
Ergo, during the CIT compared to We.P. Asia (P.) Ltd. 16 taxmann 407 (Delhi), DHC stored if such examination was applied the brand new receipt out-of express application funds regarding the about three personal limited people to have allowance out-of offers about assessee-team cannot be addressed as the receipt away from financing otherwise deposit.
Almost every other decisions wherein it has been held one to Express software funds obtained inside the dollars won’t number either in order to that loan otherwise put try VLS Meals (P
Given that share application money received because of the assessee try managed once the undisclosed money, penalty proceedings cannot was in fact started around area 269SS realize with section 271D of one’s Income-taxation Work, 1961. CIT compared to Roentgen. P. Singh and you will Co. Pvt. Ltd. 340 ITR 0217 (Del) .
Although areas 269SS and you will 269T make use of the terms “or even than of the a keen accountpayee cheque or account payee bank draft”the fresh said arrangements are meant to struck onlycash purchases (while the apparent off CBDT Game No. 387 old. 6-7-1984) we.elizabeth. ifthere was deals which are “if you don’t than just by the a free account payee cheque oraccount payee bank write” nonetheless they don’t cover people movement of money, the latest saidtransactions wouldn’t be strike by the aforesaid specifications since the demonstratedhereunder.