This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings—spanning September 2020 to September 2026—in which Section 271E of the Income Tax Act, 1961 was directly engaged. The compilation is intended for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a structured, citation-ready reference for penalty proceedings involving cash repayment of loans or deposits. Each entry records the bench, date, sections engaged, outcome direction, and a brief procedural note drawn exclusively from the source preview for that case.

Research index only. This page is a structured case-law reference drawn from tribunal records. Nothing on this page constitutes legal advice, tax advice, or professional opinion of any kind. Verify every ruling against the full judgment text before relying on it.

The statutory framework in one paragraph

Section 271E of the Income Tax Act, 1961 imposes a penalty on any person who repays any loan or deposit otherwise than in accordance with the provisions of Section 269T. Section 269T prohibits the repayment of any loan or deposit (or any specified advance) of Rs. 20,000 or more otherwise than by an account-payee cheque, account-payee bank draft, or use of electronic clearing system through a bank account. Where a contravention of Section 269T is established, the penalty leviable under Section 271E is equal to the amount of the loan or deposit so repaid. Section 273B provides that no penalty shall be imposed if the person proves that there was a reasonable cause for the failure. Section 275 governs the limitation period within which penalty proceedings must be concluded.

The 12 rulings

1. Kamal Kishor Patil,Panvel vs Income Tax Officer (5), Panvel

Bench: Income Tax Appellate Tribunal - Pune
Date: 15 September 2026
Sections engaged: 271, 271A, 271B, 271C, 271D, 271E, 271F, 272A, 272B, 273, 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Pune as ITA No.2199/PUN/2026 for Assessment Year 2019-20. Per the source preview, the assessee is an individual who had not filed a return of income for the relevant assessment year, and the case was reopened on the ground that the assessee had purchased debentures from several finance companies; the assessee's primary ground was that there was a reasonable cause for non-compliance with a notice, and the penalty levied by the Assessing Officer and confirmed by the CIT(A) should be deleted.

2. Abbayi Sunkara,Anaparthi vs Income Tax Officer, Ward-1, Kakinada

Bench: Income Tax Appellate Tribunal - Vizag
Date: 9 September 2026
Sections engaged: 143(1), 143(3), 269S, 271D, 271E, 273B, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Visakhapatnam as ITA 302/VIZ/2026 for Assessment Year 2017-18. Per the source preview, the appeal was filed by the assessee and the matter was pronounced on 09 September 2026 after a hearing concluded on 02 September 2026; the substantive details of the order are not further elaborated in the available preview.

3. DCIT, Central Circle 3, New Delhi, New vs Harish Kumar Agrawal, Uttar Pradesh

Bench: Income Tax Appellate Tribunal - Delhi
Date: 5 August 2026
Sections engaged: 271E, 275
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Delhi as ITA No.8900/DEL/2025 for Assessment Year 2020-21, arising from an order of CIT(A), Delhi-23 dated 28.10.2025. Per the source preview, the facts involve a search conducted on 17.08.2020 in the case of a group entity, following which the Assessing Officer made an addition of Rs.86.50 lakhs towards undisclosed consideration with respect to a property based on papers found during the search, and it was held that the assessee had received that amount in cash; the appeal before the ITAT engages the penalty provisions and the limitation framework under the sections listed.

4. Shree Agrawal Logistics,Gandhidham vs The ITO Ward 2 Gandhidham, Gandhidham

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 6 July 2026
Sections engaged: 271E, 269T
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Rajkot as ITA No. 608/Rjt/2026 for Assessment Year 2017-18. Per the source preview, the assessee had declared total business income as NIL for Assessment Year 2017-18; the case was selected for scrutiny and assessment was completed under the scrutiny assessment provisions by accepting the returned income, after which a rectification order was passed determining a small total income; the appeal before the ITAT arises in the context of penalty proceedings linked to the provisions governing repayment of loans and deposits.

5. Manish Sharma,Kota vs Jcit, Central Circle, Udaipur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 25 June 2025
Sections engaged: 271E, 275(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Jodhpur as I.T.A. No. 619/Jodh/2024 for Assessment Year 2011-12. Per the source preview, the core issue is whether the penalty order passed by the JCIT was time-barred by limitation; the assessee submitted that the penalty order dated 27.07.2018 was passed beyond the maximum permissible time of 30.06.2018 computed from the end of the month in which the reference to the JCIT was made, and the ITAT examined the chronology of the penalty proceedings in this context under the limitation framework.

6. Income Tax Officer, Ward-1, Kalpetta vs The Kaniyambetta Service Cooperative

Bench: Income Tax Appellate Tribunal - Cochin
Date: 7 November 2024
Sections engaged: 271D, 271E
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals were filed before ITAT Cochin as ITA Nos. 192, 193, and 172/COCH./2024, all relating to Assessment Year 2015-2016, and constituted a batch of three cases pertaining to a single assessee, Kaniyambetta Service Co.Op Bank Ltd. Per the source preview, the batch comprised Revenue's appeal (ITA No.172/COCH./2024) and the assessee's cross-appeals, with the penalty proceedings under the relevant sections forming the subject matter of the dispute.

7. Vimal Todi,Indore vs Additional Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Indore
Date: 25 October 2024
Sections engaged: 271E, 269S
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals were filed before ITAT Indore as ITA Nos. 188 to 190/Ind/2024 covering AYs 2012-13 to 2014-15. Per the source preview, the Registry noted a delay of 8 days in all three appeals; the assessee's AR submitted that the impugned orders were passed on 29.12.2023 and the last date for filing appeals was 01.03.2024, and while the appeal fee was paid on 02.02.2024, the appeal memos could not be signed in time as the assessee was travelling; the appeals proceeded on the substantive penalty questions once the delay was addressed.

8. Apcon Homes Private Limited, Dhanbad vs ACIT, Central Range-2, Ranchi

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 12 September 2024
Sections engaged: 269T, 271E
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Ranchi as ITA No.58/RAN/2023 for Assessment Year 2009-10. Per the source preview, the appeal was filed by the assessee company against the appellate order passed by the Commissioner of Income Tax (Appeals); the preview does not elaborate further on the substantive findings beyond confirming the appeal is directed against the CIT(A)'s order on the penalty matter.

9. DCIT, Centralcircle-2(2), Chennai vs Subramaniam Thanu, Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 13 March 2024
Sections engaged: 271D, 271E
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals were filed before ITAT Chennai as I.T.A. Nos. 785, 786, 787 & 788/Chny/2023 for Assessment Years 2015-16 and 2016-17, along with Cross Objections Nos. 40, 41, 42 & 43/Chny/2023. Per the source preview, the Revenue's appeals were directed against different but identical orders of the CIT(Appeals)-19, Chennai, all dated 03.05.2023, which had deleted the penalty levied by the appropriate officer under the relevant penalty provisions of the Act; the assessee filed corresponding cross-objections.

10. Deputy Commissioner Of Income vs M/S Macrotech Developers

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 29 September 2022
Sections engaged: 271D, 271E
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai and was heard on 24/08/2022 with pronouncement on 29/09/2022. Per the source preview, the text_preview contains ledger entries recording credit and debit transactions involving multiple parties across various dates in 2014 and 2015; the preview does not set out the substantive findings of the order, and accordingly only these procedural and transactional details can be noted from the available source material.

11. Shri Prem Singh S/O Shri Balvir Singh vs Joint Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 9 May 2022
Sections engaged: 271D, 271E
Outcome: Outcome not specified in source
Procedural / substantive ground: The proceedings before ITAT Amritsar involved I.T.A. Nos. 91/Asr/2020 and 718/Asr/2019 together with C.O. Nos. 1 & 2/Asr/2022, covering Assessment Years 2010-11 and 2011-12. Per the source preview, both the Revenue's appeals and the assessee's cross-objections were heard together on 21.03.2022 and pronounced on 09.05.2022; the appeal and cross-objection structure indicates that penalty issues under the relevant sections were contested by both sides.

12. The Mamurpur Co-Operative Thrift And vs Addl. CIT, Range- 38, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 10 September 2020
Sections engaged: 271D, 271E
Outcome: Outcome not specified in source
Procedural / substantive ground: The two appeals were filed before ITAT Delhi as ITA Nos. 1370 & 1371/Del./2019 for Assessment Year 2014-15, directed against two separate orders both dated 21/12/2018 passed by CIT(Appeals)-13, New Delhi. Per the source preview, the penalties had been levied by the Additional Commissioner of Income Tax, Range 38, New Delhi under Section 271D and Section 271E of the Act for violation of the provisions of Section 269SS and Section 269T respectively; the assessee is a co-operative society registered under the co-operative societies act engaged in credit activities.

Patterns across these 12 rulings

Section 271E consistently appears alongside Section 269T. Across multiple cases in this compilation — including Cases 4, 8, and 12 — Section 271E is invoked in direct conjunction with Section 269T, confirming the well-established procedural link: a penalty under Section 271E is triggered by an alleged contravention of the mode-of-repayment requirement in Section 269T.
Section 271D and Section 271E are frequently litigated together. Cases 6, 9, 10, 11, and 12 all engage both Section 271D and Section 271E in the same proceedings. This pattern reflects the common factual scenario where both the acceptance and the repayment of loans in cash are simultaneously contested, resulting in mirror-image penalty orders that travel together through the appellate process.
Limitation under Section 275 is a recurring battleground. Cases 3 and 5 specifically engage the limitation provisions (Section 275 and Section 275(1) respectively), and the source preview for Case 5 shows detailed tabular analysis of the chronology of penalty proceedings. Limitation challenges — typically arguing that the penalty order was passed beyond the permissible time computed from the date of reference — appear as a standalone ground distinct from the merits of the underlying violation.
Batch or consolidated proceedings are common. Cases 6, 7, 9, and 11 each involved multiple ITA numbers or cross-objections heard together, reflecting that Section 271E disputes often span multiple assessment years or involve both Revenue and assessee appeals arising from the same underlying facts. This consolidation pattern has practical implications for researchers tracking the full procedural history of a dispute.
Cooperative societies and real-estate entities appear as recurring assessee profiles. Cases 6, 8, and 12 involve a cooperative bank, a real-estate company, and a cooperative thrift and credit society respectively, suggesting that cash-based financial intermediation in cooperative structures and cash transactions in property dealings are among the more frequently litigated factual settings under Section 271E.

How to use this compilation

This index is intended as a starting point for legal research, not as a substitute for reading the full judgment. Each ruling listed above should be independently verified against the complete order text available on the Income Tax Appellate Tribunal's official website or on indiankanoon.org. The "Outcome not specified in source" designation for all twelve cases reflects the limits of the structured extract available in the source corpus — it does not mean the appeal was dismissed or allowed; the full order must be consulted to determine the operative direction of the ruling.

Researchers should also check whether any of these orders have been subsequently stayed, reversed, or affirmed by a High Court or the Supreme Court. ITAT orders on penalty matters under Section 271E are routinely carried further in appeal, particularly where the quantum is significant or where a limitation argument has succeeded at the tribunal level. Before treating any ruling as representing settled law, confirm its current appellate status using the court's cause-list records or a litigation-tracking service.

Finally, CBDT circulars and instructions bearing on Section 269T, Section 271E, and the reasonable-cause defence under Section 273B should be read alongside any judicial ruling. Circular positions on what constitutes "reasonable cause," or on the applicability of penalty provisions to specific categories of assessees (such as cooperative societies), may affect how tribunals approach these cases and could qualify the precedential weight of individual rulings in your specific fact situation.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 271E Penalty: 12 ITAT Rulings on Cash Loan Repayment Violations