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    <title>2025 (8) TMI 620 - ITAT COCHIN</title>
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    <description>The ITAT Cochin upheld the penalty under section 271D for violation of section 269SS, ruling that penalty proceedings were initiated and concluded within the prescribed limitation period. The Tribunal rejected the contention that the assessment order initiation was invalid, relying on the jurisdictional HC precedent. It was held that cash sale consideration disclosed during search operations, which was significantly higher than the declared amount, fell within the ambit of section 269SS. The assessee&#039;s failure to disclose actual capital gains and reasonable cause led to confirmation of the penalty. The appeal was dismissed, affirming the penalty levy under sections 271D read with 274.</description>
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    <pubDate>Wed, 06 Aug 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 620 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=776433</link>
      <description>The ITAT Cochin upheld the penalty under section 271D for violation of section 269SS, ruling that penalty proceedings were initiated and concluded within the prescribed limitation period. The Tribunal rejected the contention that the assessment order initiation was invalid, relying on the jurisdictional HC precedent. It was held that cash sale consideration disclosed during search operations, which was significantly higher than the declared amount, fell within the ambit of section 269SS. The assessee&#039;s failure to disclose actual capital gains and reasonable cause led to confirmation of the penalty. The appeal was dismissed, affirming the penalty levy under sections 271D read with 274.</description>
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      <pubDate>Wed, 06 Aug 2025 00:00:00 +0530</pubDate>
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