2025 (10) TMI 571

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.... the order passed by learned CIT(A) u/s 271D of the Act is bad in law. 2. Whether on the facts and in law, the learned CIT(A) erred in upholding the action of learned AO in making an addition of Rs. 12,00,000/- u/s 271D of the Act to income of the assessee, ignoring the facts of the case as well as submissions and documentary evidence filed by the assessee. 3. Whether on the facts and in law, the learned CIT(A) erred in not condoning the delay in filing the appeal. 4. The Assessee craves to add, alter, vary, omit, amend or delete one or more of the above grounds of appeal before, or at the time of, hearing of the appeal, so as to enable the Hon'ble Tribunal to decide this appeal according to the law." 2. Du....

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....d a piece of land against the sale consideration of Rs. 12 lakh and received the same in cash and the same was offered to tax, whereas the fair market value of the property was Rs. 15,71,500. The Assessing Officer, however, observed that the assessee had accepted cash of Rs. 12 lakh, which is above Rs. 20,000, is in contravention of provisions under section 269SS of the Act, and accordingly proceeded to levy penalty under section 271D of the Act. 6. On appeal, before the learned CIT(A) the assessee filed detailed submissions which was considered by the learned CIT(A), however, the same was not found tenable on account of the following:- "The assessee's claim that the amount of sale consideration to the tune of Rs. 12 lakhs w....