Friday, December 5, 2014

Section 269T Repayment of Loans or Deposits

42[Mode of repayment of certain loans or deposits43.
269T. No branch of a banking company or a co-operative bank and no other company or co-operative society and no firm or other person shall repay any loan or deposit made with it otherwise than by an account payee cheque or account payee bank draft drawn in the name of the person who has made the loan or deposit if—
(a)  the amount of the loan or deposit together with the interest, if any, payable thereon, or
(b) the aggregate amount of the loans or deposits held by such person with the branch of the banking company or co-operative bank or, as the case may be, the other company or co-operative society or the firm, or other person either in his own name or jointly with any other person on the date of such repayment together with the interest, if any, payable on such loans or deposits,
is twenty thousand rupees or more:

Provided that where the repayment is by a branch of a banking company or co-operative bank, such repayment may also be made by crediting the amount of such loan or deposit to the savings bank account or the current account (if any) with such branch of the person to whom such loan or deposit has to be repaid :
44[Provided further that nothing contained in this section shall apply to repayment of any loan or deposit taken or accepted from—
(i)  Government;
(ii)  any banking company, post office savings bank or co-operative bank;
(iii) any corporation established by a Central, State or Provincial Act;
(iv) any Government company45 as defined in section 617 of the Companies Act, 1956 (1 of 1956);
(v) such other institution, association or body or class of institutions, associations or bodies which the Central Government may, for reasons to be recorded in writing, notify in this behalf in the Official Gazette.]
Explanation.—For the purposes of this section,—
(i)  "banking company" shall have the meaning assigned to it in clause (i) of the Explanation to section 269SS;
(ii)  "co-operative bank" shall have the meaning assigned to it in Part V of the Banking Regulation Act, 1949 (10 of 1949);
(iii) "loan or deposit" means any loan or deposit of money which is repayable after notice or repayable after a period and, in the case of a person other than a company, includes loan or deposit of any nature.]
42. Substituted by the Finance Act, 2002, w.e.f. 1-6-2002. Prior to its substitution, section 269T was inserted by the Income-tax (Second Amendment) Act, 1981, w.e.f. 11-7-1981 and later on amended by the Finance Act, 1984, w.e.f. 1-4-1984, Finance Act, 1985, w.e.f. 1-4-1986 and Direct Tax Laws (Amendment) Act, 1987, w.e.f. 1-4-1989.
43. For the meaning of the term "deposit", see Taxmann's Direct Taxes Manual, Vol. 3. See also Circular No. 479, dated 16-1-1987, Circular No. 522, dated 18-8-1988 and Circular No. 556, dated 23-2-1990. For details, see Taxmann's Master Guide to Income-tax Act.
44. Inserted by the Finance Act, 2003, w.r.e.f. 1-6-2002.
45. For definition of "Government company"

Q : Whether the Section 269T is applicable when the partners withdrew the capital in cash from the partnership firm ?
Answer:-  Where partners of firm gives money to firm in need of business exigencies and received it back through capital account, both in cash; no penalty could be levied Deputy Commissioner of Income-tax v. Chetan M. Kakaria [2014] 49 taxmann.com 490 (Mumbai - Trib.) IN THE ITAT MUMBAI BENCH 'C'
Q: When the Cash credit loan taken in cash is treated as unexplained and added in the income of the Assessee, whether the penalty can also be levied for violaton of Section 269T i.e receipt and repayment of this loan in cash ?
Answer : No, Section 68, read with sections 269SS, 269T and 271D, of the Income-tax Act, 1961 - Cash credits (Loan) - Assessment years 2008-09 and 2009-10 - During relevant year, Assessing Officer noted that assessee, to get over certain financial difficulties, borrowed a sum of Rs. one crore in cash - Assessee repaid Rs. 50 lakhs during relevant years - Assessing Officer taking a view that it was a case of unexplained cash receipt, treated amount in question as assessee's own income - He thus added said amount to assessee's income under section 68 - Assessing Officer also passed a penalty order under section 271D for violating provisions of section 269SS - Whether once amount was subjected to tax under section 68, question of treating it as transaction in violation of section 269SS or section 269T did not arise as it stood mutually excluded - Held, yes - Whether, therefore, impugned penalty order was to be set aside - Held, yes [Para 7] [In favour of assessee] Director of Income-tax (Exemptions), Chennai v. Young Men Christian Association [2014] 49 taxmann.com 72 (Madras) HIGH COURT OF MADRAS
Q : When the customers had given earnest money (booking advance) to the Assessee for purchase of shop/office/flat in cash/ cheque whether its repayment in cash can be condiered as violation of Section 269 T ?
Answer: No, Section 269T, read with section 271E of the Income-tax Act, 1961 - Deposit - Mode of repayment [Earnest money] - Assessment year 2006-07 - Whether, where assessee-company, engaged in construction, repaid earnest money/advances to certain parties in cash, section 269T was not applicable as repayments were not in nature of repayment of loan or deposits - Held, yes -Whether, therefore penalty under section 271E for violation of section 269T, for making payments in excess of Rs. 20,000 in cash, could not be levied - Held, yes [Para 7] [In favour of assessee]. Commissioner of Income-tax –VI v. Madhav Enterprise (P.) Ltd. [2013] 37 taxmann.com 349 (Gujarat) HIGH COURT OF GUJARAT
Q: When the sister partnership firm receive/ repay the money in cash from/to another sister partnership firm , whether the same is violation of section 269 SS or 269 T and hence liable for penalty u/s 271D or Section 273B ?
Answer :No. Where assessee-firm received a sum of Rs. 4.35 lakhs in cash from its sister concern and repaid a sum of Rs. one lakh in cash to sister concern, transfer of cash by one firm to another would operate as a reasonable cause and, therefore, levy of penalty under sections 271D and 271E upon assessee was not justified. K.K. Enterprises v. Joint Commissioner of Income-tax, Range-25(2) [2014] 41 taxmann.com 235 (Mumbai - Trib.) IN THE ITAT MUMBAI BENCH 'A'
Q Whether before levying penalty under section 271E, Assessing Officer should record finding about availability of banking facilities and other explanation offered by assessee for making payment by cash instead of cheque ?
Answer Yes, Section 269T, read with section 271E, of the Income-tax Act, 1961 - Deposits/loans, mode of taking [Reasonable cause] - Assessment year 2005-06 - Assessee repaid loan to creditors in cash exceeding Rs. 20,000 - Assessing Officer levied penalty under section 271E - Tribunal found that assessee should have been given some opportunity to prove that there was reasonable cause for non-compliance with statutory provisions of section 269T and there being no finding about availability or otherwise of banking facilities in and around place where payment of loan had been made, it remanded matter to assessing authority to record a finding thereabout and then to pass appropriate orders - Whether order of Tribunal being only an order of remand, same could not be interfered with in appeal - Held, yes [Para 7] [In favour of assessee] Commissioner of Income-tax v. K. Srinivasulu Reddy [2013] 38 taxmann.com 201 (Karnataka) HIGH COURT OF KARNATAKA
Q When the Repyament of Loan / deposit is made by book entries whether penalty can be imposed under section 271E ?
 Answer :when the repayment of loan/deposit was  a bona fide transaction, adjustement in the books of  accounts can be made through journal entries and No penalty can be imposed under Section 271E .
Section 271E, read with section 273B, of the Income-tax Act, 1961 - Penalty - For failure to comply with section 269T - Assessment year 2003-04 - Whether where loan/deposit has been repaid by debiting account through journal entries, it must be held that assessee has contravened provisions of section 269T - Held, yes - Assessee was engaged in share trading business - It had taken loan from Investment Trust of India - During relevant assessment year, it had transferred some shares to said trust - Instead of repaying loan and receiving sale price of shares, both parties agreed that said amount, i.e., loan and sale consideration be set off in their respective books by making journal entries - Whether assessee had repaid loan/inter-corporate deposit in contravention of provisions of section 269T - Held, yes - Whether, however, in absence of finding to effect that repayment of loan/deposit was not a bona fide transaction and was made with view to evade tax, no penalty under section 271E could be imposed for contravening provisions of section 269T - Held, yes [In favour of assessee] Commissioner of Income-tax, Central-IV v. Triumph International Finance (I) Ltd. [2012] 22 taxmann.com 138 (Bom.) HIGH COURT OF BOMBAY
Question : when the amount is mount received by assessee in cash  only for purpose of allotment of shares, whether its repayment in cash violate the provisions of Section 269T ?
Answer No the assessee had a reasonable cause as the assessee was under the bona fide belief that the money received was only for the purpose of allotment of shares and also there was no material or evidence or any compelling reason produced by the revenue to prove that the money received was a deposit or loan; as such levy of penalty on the assessee under section 271E was not justified, particularly since no interest was paid by the assessee on any such advance. Commissioner of Income-tax v Rugmini Ram Ragav Spinners (P.) Ltd. [2008] 304 ITR 417 (MAD.) HIGH COURT OF MADRAS

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