ITAT Deletes Section 271D Penalty as Cash Sale Consideration Is Not Covered by Section 269SS

Mohammed Shabbir Bhojani Vs ITO (ITAT Hyderabad) Core Issue: The primary issue was whether cash received as sale consideration for immovable property attracts penalty under Section 271D for violation of Section 269SS, and secondly, whether penalty can be levied without recording satisfaction in assessment proceedings. Facts: The assessee, engaged in real estate business, sold multiple properties and received consideration partly in cheque and partly in cash at the time of registration before the Sub-Registrar. No regular assessment proceedings were conducted, yet the JCIT levied penalty of ₹...