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    <title>2026 (4) TMI 116 - ITAT HYDERABAD</title>
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    <description>Penalty under section 271D was held time-barred under section 275(1)(c) because limitation ran from the Assessing Officer&#039;s reference for penalty during assessment proceedings, not from the later notice by the Joint Commissioner; the order was therefore beyond the six-month period and quashed. On merits, penalty was also found unsustainable because the cash receipt arose from a genuine sale of agricultural land, the consideration was reflected in the registered sale deed and return, and there was no indication of concealment or black money. The transaction was treated as covered by reasonable cause under section 273B, so penalty was deleted.</description>
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      <title>2026 (4) TMI 116 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=789047</link>
      <description>Penalty under section 271D was held time-barred under section 275(1)(c) because limitation ran from the Assessing Officer&#039;s reference for penalty during assessment proceedings, not from the later notice by the Joint Commissioner; the order was therefore beyond the six-month period and quashed. On merits, penalty was also found unsustainable because the cash receipt arose from a genuine sale of agricultural land, the consideration was reflected in the registered sale deed and return, and there was no indication of concealment or black money. The transaction was treated as covered by reasonable cause under section 273B, so penalty was deleted.</description>
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