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    <title>2026 (5) TMI 179 - ITAT HYDERABAD</title>
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    <description>Cash received as sale consideration in a registered immovable property transaction was held not to constitute a loan, deposit or specified sum within section 269SS, because it formed part of completed sale consideration recorded in the sale deeds; penalty under section 271D was therefore not leviable on that substantive ground. Penalty proceedings were also invalid because initiation under section 271D requires recorded satisfaction in assessment or other proceedings, and no such satisfaction had been recorded by the Assessing Officer; the jurisdictional precondition for penalty was thus absent. On both substantive and procedural grounds, the penalty could not be sustained.</description>
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    <pubDate>Thu, 30 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 179 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=790977</link>
      <description>Cash received as sale consideration in a registered immovable property transaction was held not to constitute a loan, deposit or specified sum within section 269SS, because it formed part of completed sale consideration recorded in the sale deeds; penalty under section 271D was therefore not leviable on that substantive ground. Penalty proceedings were also invalid because initiation under section 271D requires recorded satisfaction in assessment or other proceedings, and no such satisfaction had been recorded by the Assessing Officer; the jurisdictional precondition for penalty was thus absent. On both substantive and procedural grounds, the penalty could not be sustained.</description>
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      <pubDate>Thu, 30 Apr 2026 00:00:00 +0530</pubDate>
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