Mohammed Shabbir Bhojani vs. ITO, Ward-9(1), Hyderabad, ITA No. 2317/Hyd/2025, order dated 30.04.2026 (ITAT Hyderabad)
Core Issue: The primary issue was whether cash received as sale consideration for immovable property attracts penalty under Section 271D for violation of Section 269SS, and secondly, whether penalty can be levied without recording satisfaction in assessment proceedings.
Facts: The assessee, engaged in real estate business, sold multiple properties and received consideration partly in cheque and partly in cash at the time of registration before the Sub-Registrar. No regular assessment proceedings were conducted, yet the JCIT levied penalty of ₹36,00,000 under Section 271D alleging violation of Section 269SS.
AO / Department’s Findings:
The Department held that cash receipt constitutes “specified sum” under Section 269SS, and since the amount exceeded ₹20,000, penalty u/s 271D equal to cash received was leviable. It was argued that JCIT has independent jurisdiction to initiate penalty based on information from Investigation Wing, even without assessment proceedings.
CIT(A) Decision: The CIT(A) confirmed the penalty, accepting the view that cash received in property transactions violates Section 269SS, and upheld the validity of penalty proceedings initiated by JCIT.
ITAT Findings: The ITAT deleted the penalty on two decisive grounds. First, it held that cash received as sale consideration at the time of execution of registered sale deed does NOT fall within the ambit of Section 269SS, as the provision targets loans, deposits, or advances (specified sum), not completed sale transactions. Second, the Tribunal held that penalty proceedings are invalid in absence of assessment proceedings or recorded satisfaction by the Assessing Officer, which is a mandatory jurisdictional requirement. Thus, the penalty u/s 271D was held unsustainable in law.
Cases Relied Upon: The Tribunal relied on key precedents including emphasizing that recording of satisfaction in assessment proceedings is sine qua non for penalty initiation.
Final Outcome: The appeal of the assessee was allowed, and penalty u/s 271D was quashed on both merits and jurisdictional grounds.
Ibn al-Qayyim
“From Allāh’s mercy upon His servant is that He tests him with a trial which he can’t disclose to others nor can he find anyone who can understand it properly — so that his heart doesn’t become attached to anyone else instead of Allāh who he goes and complains to.”
If you want to talk to Allah, perform Salah. If you want Allah to talk to you, read the Qur'an. Don't abandon the opportunity to connect with your Creator.
ICAI has introduced the Business Accounting Associate (BAA) Certificate, marking an important shift for CA students who are unable to complete the Final level.
This initiative acknowledges that even if the CA journey is not completed in full, the effort and learning gained along the way still hold professional value.
✅ Students who have cleared both groups of CA Intermediate, completed Articleship, finished ICITSS, and cleared the Self-Paced Modules can apply through the SSP portal under Student Services to obtain this certificate.
The BAA aims to provide a formal professional identity, recognize practical training and Intermediate-level knowledge, and create a viable pathway into accounting and finance roles.
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This image reflects the idea that power in the world often operates through hidden layers rather than what we see on the surface. At the very top are powerful forces of wealth, ideology, and influence that rarely appear in public view but shape major systems.
Instead of ruling directly, they influence institutions, policies, and global directions from behind the curtain. World leaders then become the visible faces of decisions, acting as the public authority that people believe controls everything.
Beneath them, media, celebrities, sports stars, and entertainment industries help shape narratives, trends, and public attention. Through constant information streams and screens, emotions, beliefs, and opinions of billions of people can be guided.
The public consumes these stories and narratives daily, often unaware of the deeper structures influencing them. Power therefore moves like a chain of puppets, where influence flows from the top through multiple layers before reaching society. The real depth of this image lies in showing how perception itself can be shaped and controlled..and awareness begins when people start questioning what they see, think independently, and look beyond the surface of the system.