Held that the assessee-company is unable to establish on the basis of any evidence that the disputed loans received in cash were even genuine loan transactions. Violations of section 269SS and section 269T of the Act, which deal with the modes of accepting certain loans deposits and specified sums, and the modes of repayment of certain loans for deposits, respectively, are not to be examined from the perspective of the person who has given the loan or to whom the loan was returned but from the perspective of the recipient of the loan. Thus, the innocence pleaded on account of ignorance of law of directors who claimed to be non-resident was insignificant. There was no question of any benefit to the assessee-company on the basis of claim of bona fides of the directors. The provisions of sections 269SS and 269T of the Act imposed a statutory liability and could not be said to held to be mere technical violation in the case of companies. Penalty is confirmed. (AY.2002-03)