Reasonable cause for delay in wealth-tax return filing can defeat penalty where forms were unavailable and valuation reports delayed filing.

Delay in filing a wealth-tax return under section 18(1)(a) was treated as covered by reasonable cause where the assessee cited non-availability of return forms, the time needed to obtain a valuer's report, and related filing difficulties. The explanations were said to have been placed before the authorities but not properly considered, and the Revenue did not disprove them. On that basis, the causes were found to have a direct nexus with the delay, so the penalty provisions were not attracted and the penalty was cancelled.

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Issues: Whether the penalty imposed for delay in filing the wealth-tax return under section 18(1)(a) of the Wealth-tax Act, 1957 was sustainable when the assessee explained the delay by reference to non-availability of return forms, time taken to obtain a valuer's report, and related difficulties.

Analysis: The delay was found to be supported by more than one cause placed before the authorities, including the request for extension on account of unavailable return forms and the subsequent obtaining of a valuer's report before filing the return. These explanations were not considered by the authorities below, and the Revenue did not disprove them. The causes shown were treated as reasonable and as having a direct nexus with the delay.

Conclusion: The assessee had reasonable cause for the delay, so the penalty provisions were not attracted and the penalty was cancelled.

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