Dy. CIT v. Ira Wasson (2025) 127 ITR 344 / 171 taxmann.com 840 (Delhi)(Trib.)

S. 271D : Penalty-Takes or accepts any loan or deposit-Legal heir-Cash loans accepted or repaid by company-Legal heir not liable for acts of deceased director.[S. 159(6), 269SS, 269ST, 271E]

Penalty under sections 271D and 271E was levied on the assessee as legal heir of her deceased husband, who was a director of a company alleged to have accepted and repaid loans in cash in violation of sections 269SS and 269ST. The Tribunal held that the assessee was neither a director nor a shareholder of the company and no material was brought on record to establish her involvement in the transactions. She had not inherited any estate or benefit attracting liability under section 159(6). The penalties were therefore rightly deleted. (AY. 2014-15 to 2017-18).

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