Extended limitation requires willful misstatement or suppression with intent to evade; mere misclassification does not sustain confiscation or penalty...
The article addresses penalty proceedings under section 271D for alleged contravention of section 269SS: tribunals have held that cash received as part of sale consideration expressly recorded in a registered sale deed may fall outside the prohibition on specified cash receipts, and penalty cannot stand where the Assessing Officer has not recorded satisfaction in assessment proceedings. It further notes limitation rulings applying the TOLA extension as making show-cause notices issued well after the extended reasonable period time-barred; on those grounds the impugned penalty was deleted and the assessee's appeal allowed.
The article addresses penalty proceedings under section 271D for alleged contravention of section 269SS: tribunals have held that cash received as part of sale consideration expressly recorded in a registered sale deed may fall outside the prohibition on specified cash receipts, and penalty cannot stand where the Assessing Officer has not recorded satisfaction in assessment proceedings. It further notes limitation rulings applying the TOLA extension as making show-cause notices issued well after the extended reasonable period time-barred; on those grounds the impugned penalty was deleted and the assessee's appeal allowed.
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