Reasonable cause defeats tax penalty where delayed payment is backed by bona fide facts and supporting evidence.

Penalty under a taxing statute expressed to apply only where default occurs "without reasonable cause" depends on whether the assessee had a bona fide and factually supported explanation for delayed payment. On the facts recorded, the assessee issued cheques expecting payment from the Electricity Board, the cheques were dishonoured before realization, and tax with interest was paid soon after funds were received. The Tribunal accepted this explanation on the evidence, and that factual finding negatived penalty liability under Section 15-A(1)(a).

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Issues: Whether penalty under Section 15-A(1)(a) of the Sales Tax Act was justified when the assessee failed to deposit admitted tax within time, and whether the assessee had shown reasonable cause for the delay.

Analysis: The statutory phrase "without reasonable cause" makes the existence of sufficient cause a decisive factor in penalty proceedings. On the facts found, the assessee issued cheques in the expectation of receiving payment from the Electricity Board, the cheques were dishonoured before realization, and payment of tax with interest was made shortly thereafter when funds were received. The Tribunal's acceptance of this explanation was based on materials on record and involved a factual finding that reasonable cause existed.

Conclusion: Penalty under Section 15-A(1)(a) was not exigible, and the Tribunal was right in deleting the penalty. The revisions failed.

Ratio Decidendi: Where the taxing statute makes penalty dependent on failure to act "without reasonable cause", a bona fide and factually supported explanation for delayed tax payment negatives penalty liability.

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