Reasonable cause for delayed return filing left no question of law for tax reference

The Tribunal accepted the explanation for delay in filing the return and treated the negligence of the person handling the return as reasonable cause, so no penalty was imposable. On that factual foundation, the High Court held that no question of law arose from the Tribunal's order for reference under section 256(2) of the Income-tax Act, 1961, and rejected the reference application.

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Issues: Whether, on the facts found by the appellate authority and the Tribunal, any question of law arose warranting a reference under section 256(2) of the Income-tax Act, 1961.

Analysis: The appellate authority and the Tribunal had accepted the explanation for the delay in filing the return and held that the negligence of the person handling the return constituted reasonable cause, so that no penalty was imposable. On that factual foundation, the Court found no legal question arising from the Tribunal's order.

Conclusion: No question of law arose out of the Tribunal's order and the application for reference was rejected.

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