Court held that the Tribunal in its findings had primarily relied on entries in the books of account that the two cash payments were imprest, and therefore neither loan nor deposit. It had not considered and noticed specific aspects referred to in the order of penalty under section 271D and the observations and findings of the Commissioner (Appeals) holding that the contention and claim of imprest was a sham and facile. Accordingly the penalty order was set aside and the matter was remanded to the Tribunal. ( AY.1999-2000)