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    <description>Penalty under section 271(1)(c) was held unsustainable because the disputed amount was not taxable as capital gains on the facts already covered by the earlier ruling on the same development-agreement transaction. The Court applied its prior reasoning that, without a registered agreement meeting the requirements of section 53A of the Transfer of Property Act, section 2(47)(v) of the Income-tax Act did not treat the entire consideration as accrued or taxable in the relevant year. As no capital gains were exigible on the unrealized amount, the basis for alleging concealment or furnishing inaccurate particulars was absent.</description>
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      <link>https://www.taxtmi.com/caselaws?id=345847</link>
      <description>Penalty under section 271(1)(c) was held unsustainable because the disputed amount was not taxable as capital gains on the facts already covered by the earlier ruling on the same development-agreement transaction. The Court applied its prior reasoning that, without a registered agreement meeting the requirements of section 53A of the Transfer of Property Act, section 2(47)(v) of the Income-tax Act did not treat the entire consideration as accrued or taxable in the relevant year. As no capital gains were exigible on the unrealized amount, the basis for alleging concealment or furnishing inaccurate particulars was absent.</description>
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