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    <title>2026 (4) TMI 116 - ITAT HYDERABAD</title>
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    <description>Section 275(1)(c) was applied to hold that limitation for penalty under Section 271D runs from the month in which the Assessing Officer initiates penalty action by reference, not from the later show-cause notice, so the penalty order was time-barred. On the merits, cash consideration received for a genuine sale of agricultural land, duly recorded in the registered deeds and books and unsupported by any material of unaccounted income or tax evasion, was treated as outside penal consequence on these facts. The assessee also established reasonable cause and bona fide belief under Section 273B, so the penalty under Section 271D 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>Section 275(1)(c) was applied to hold that limitation for penalty under Section 271D runs from the month in which the Assessing Officer initiates penalty action by reference, not from the later show-cause notice, so the penalty order was time-barred. On the merits, cash consideration received for a genuine sale of agricultural land, duly recorded in the registered deeds and books and unsupported by any material of unaccounted income or tax evasion, was treated as outside penal consequence on these facts. The assessee also established reasonable cause and bona fide belief under Section 273B, so the penalty under Section 271D was deleted.</description>
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