Honble LAKSHMANAN, CJ.–This appeal is filed by the Department questioning the correctness of the order passed by the Income Tax Appellate Tribunal confirming the order of the CIT (Appeals). The question posed for our consideration is whether the amount credited to the account of M/s Ramchander Banarsidass is a deposit or a loan or a trade in transaction? (2). The Commissioner of Income Tax, on a detailed consideration of the factual matrix of the matter and also the provisions of section 269T, came to the conclusion that the book entries so made by the respondents with reference to the payment made on its behalf by the other party was at the most a type of accommodation, or loan and not a deposit which otherwise is contemplated by Sec. 269T. In view of this, the Commissioner held that there was no justification in treating the respondents to have contravened the provisions of Sec. 269T which otherwise was really not applicable on account of actual transaction being by way of accommodation in the form of loan and not a deposit. Sec. 269T, specifically refer to the repayment of deposit whereas the provisions of Sec. 269SS refer to loan or deposit. This itself, as pointed out by the commissioner, would indicate that the legislature had kept in view the subtle distinction between loan and deposit while framing the provisions of Sec. 269T and Sec. 269SS. (3). The Income Tax Appellate Tribunal, on appeal by the Income Tax Officer, confirmed the decision of the Commissioner of Income Tax. Both, the Commissioner, as well as the appellate Tribunal, on consideration of the entire factual circumstances of the case, came to the conclusion that it is only a type of loan transaction or a type of accommodation and not a deposit which otherwise is contemplated by Sec. 269T. When a factual finding is arrived at by the authorities concerned, it is not proper for this Court of reappreciate the same and take a different view. (4). In our opinion, there is not justification in treating the transaction in question, as a deposit. The respondents, in our opinion, has not contravened the provisions of Sec. 269T. (5). The appeal, therefore, bails and is dismissed.