(1.) IN this petition under Articles 226 and 227 of the Constitution, there is challenge to the constitutional validity of Sections 269SS and 271D of the INcome-tax Act, 1961 (for short "the Act"). These two Sections may be set out as under :
(2.) WE may, however, note that prior to the Direct Tax Laws (Amendment) Act, 1987, which came into force with effect from April 1, 1989, the amount of such loan or deposit was rupees ten thousand or more. Section 269SS itself was inserted by the Finance Act, 1984. By the same amending Act, 1987, Section 271D was inserted and at the same time Section 276DD which provided for punishment for failure to comply with the provision of Section 269SS was omitted,