2026 (7) TMI 132

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....jay Singh, Sr. DR ORDER PER YOGESH KUMAR U.S., JUDICIAL MEMBER: This Appeal is filed by the Assessee against the order of the NFAC, Delhi ["the Ld. CIT(A)", for short], dated 17.02.2026 passed u/s 250 of the Income Tax Act, 1961 ("the Act", for short) for the assessment year 2013-14. 2. Brief facts of the case as mentioned in the Order of the Ld. CIT(A) is as under: - "The app....

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....ous customers on various dates as advance for residential building named as "Friends Villa". The assessee contested that the return of income u/s. 148 was filed on 26.04.2021. The e-filing access of the department showed the return of income filed u/s. 119(2)(b) and therefore, it was treated as invalid. Due to technical glitches, the system showed wrong section resulting into invalidating the retu....

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....ion 271D of the Act while imposing the penalty, holding that the Assessee had accepted 'advance for customer' in cash to the tune of Rs. 69,81,516/- which is more than Rs. 20,000/-, therefore, the same attracts section 269SS of the Act. However, the definition for words "specified sum" in section 269SS of the Act has been substituted in the Finance Act, 2023 with effect from 01.04.2023. Therefore,....

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....und that the Assessee has received consideration in cash which is more than Rs. 20,000/-, which is in violation of section 269SS of the Act. It is specific case of the Assessing Officer that the said violation made by the Assessee is covered under the definition of "specified sum" as per explanation (iv) to section 269SS of the Act. However, the said explanation defining "specified sum" in section....