Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
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