Reasonable cause for non-payment of self-assessment tax upheld where financial stringency made the Tribunal's factual view sustainable.

The Tribunal's acceptance of the assessee's explanation for non-payment of self-assessment tax under the Wealth-tax Act was upheld because financial stringency was treated as a reasonable and sufficient cause. The High Court held that the Tribunal's conclusion was a possible view on the facts, and therefore no interference was warranted. The finding was characterised as a factual determination made by applying the Supreme Court's criteria in Hindustan Steel Ltd. v. State of Orissa.

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Issues: Whether the Tribunal was right in accepting the assessee's explanation for failure to pay self-assessment tax under section 15B of the Wealth-tax Act and in holding that no interference was called for.

Analysis: The assessee's case before the appellate authorities was that financial stringency prevented payment of the tax, the property having been acquired earlier and compensation being received much later. The Tribunal accepted this explanation as reasonable and sufficient. The Court found that, even if fuller facts might have led to a different view, the Tribunal's conclusion was a reasonable and possible one. The finding was treated as a finding of fact, arrived at by applying the criteria laid down by the Supreme Court in Hindustan Steel Ltd. v. State of Orissa.

Conclusion: The Tribunal's acceptance of the assessee's explanation was upheld and no interference was warranted.

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