Penalty under Section 271D and 274 upheld for concealed cash sale consideration within limitation period

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....The ITAT upheld the imposition of penalty under section 271D read with section 274, confirming the penalty proceedings were initiated within the statutory limitation period. The AO's reference to the JCIT on 11/10/2022 and subsequent penalty order on 28/04/2023 fell well within the six-month limitation from initiation. The Tribunal rejected the contention that the AO was incompetent to initiate proceedings, relying on authoritative jurisdictional precedent. The assessee's failure to disclose the actual sale consideration, revealed only post search and seizure, was held to demonstrate concealment and lack of reasonable cause. The Tribunal affirmed that cash receipt of sale consideration at registration falls within the ambit of "other sums" .........