Corroborated agreement to sell sustains addition, but cash consideration in completed sale deed falls outside section 269SS penalty

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....A seized photocopy of an agreement to sell was treated as reliable incriminating material where it was signed on every page, witnessed, and matched the subsequent registered sale deeds on consideration details, cheque particulars and witness identity; the Tribunal held that no further independent corroboration was required and sustained the addition for under-reported sale consideration. For penalty, it held that cash paid at the time of execution of a registered sale deed is distinct from the advance or specified sum targeted by the amended section 269SS, which was intended to curb cash advances in real-estate transactions; on that basis, penalty under section 271D was deleted.....