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2024 (9) TMI 1790

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....rnalatha, Sr. DR ORDER PER SATBEER SINGH GODARA, J.M. : This assessee's appeal, for assessment year 2017- 2018, arise against the National Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/2023- 24/1055552017(1), dated 29.08.2023, in proceedings u/s.271D of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties at length. Case file perused. 2....

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.... arguments. We make it clear that the assessee had duly filed all the supportive details of the vendee concerned which have nowhere been disputed. Faced with this situation, it further emerges that this tribunal's learned coordinate bench's order in ITA.No.488/Hyd./2023 Ramkumar Reddy Satty vs. ACIT dated 19.03.2024 holds that such cash receipts in immovable property transaction(s) indeed form rea....

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....269SS of the Act, only applicable for advance receivable, namely, 'as advance or otherwise' means advance can be in any manner, and therefore, this provision will not apply to the transaction that happens when the final payment at the time of registration of sale deed and payment takes place before sub-registrar for registration of property. Relevant part of para No.12.1 of the decision of....

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....er. Hence, this provision will not apply to the transaction that happens at the time of final payment at the time of registration of sale deed and payment is made before sub-registrar at the time of registration of property. In the present case before us, it is an admitted fact that all sale deeds were registered and cash payment was made at one go before the sub- registrar at the time of registra....