(1.) ITA 221/2003
(2.) THIS appeal by the Revenue under Section 260A of the Income Tax Act, 1961 ('Act' in short) was admitted for hearing vide order dated 21.09.2004 on the following substantial question of law: -
(3.) IN the first appeal, the Commissioner of Income Tax (Appeals) sustained the penalty in respect of book entry of Rs. 33,75,842/ - but restored for fresh examination, the entry relating to K.N Bhalla, in view of the submission that the debit entry in the name of K.N Bhalla did not create any liability towards any new loan or deposit. The submission was that it was a mere transfer entry with name of K.N Bhalla being substituted for M/s. Quality Clothiers.