2025 (12) TMI 488

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....the Respondent: Smt. Leena Lal, Snr AR ORDER PER MANU KUMAR GIRI (Judicial Member): The captioned appeal filed by the assessee is directed against order of the Ld. Commissioner of Income Tax (Appeal)/NFAC, Delhi ['CIT(A)' in short] dated 16.09.2025 for Assessment Year 2017-18 confirming imposition of penalty u/s. 271D of the Income tax Act, 1961 ('Act' in short). 2. Brief facts are tha....

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....in cash at the time of completing the registration formalities. The assessee had no bargaining power and was under pressure to complete the transaction as registration was already scheduled and both parties were present. He immediately deposited the entire cash into his bank on the same day. The full sale consideration (including cash) was properly disclosed in the return of income. The entire sal....

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....ource of funds are accepted, and there is no intention to evade tax, penalty u/s. 271D should not be imposed. Section 271D is not meant to punish technical or venial breaches but only serious violations with mala fide intent (Hindustan Steel Ltd. 83 ITR 26 SC). The Hon'ble Bombay High Court in the cases of Ajitnath Hitech Builders 416 ITR 316 and Triumph International Finance, INCOME TAX APPEAL NO....