09/07/2026
Cash Received on Property Sale: Can Section 271D Penalty Apply? ITAT Hyderabad Gives Major Relief - If cash is received as part of the sale consideration at the time of registration of a sale deed, can the Income Tax Department levy penalty under Section 271D for violation of Section 269SS? ITAT Hyderabad in Mohammed Shabbir Bhojani vs ITO deleted Section 271D penalty, holding that cash received as final property sale consideration at registration does not attract Section 269SS penalty where no AO satisfaction was recorded. The Tribunal deleted the penalty of ₹36,00,000 under Section 271D and gave an important ruling on the scope of Section 269SS in immovable property transactions.
ITAT Hyderabad in Mohammed Shabbir Bhojani vs ITO deleted Section 271D penalty, holding that cash received as final property sale consideration at registration does not attract Section 269SS penalty where no AO satisfaction was recorded.