Reasonable cause for not filing a revised advance-tax estimate defeated penalty where notice was understood as personal to the deceased.

Penalty under section 273(c) was held unsustainable where the assessee failed to file a revised estimate of advance tax under section 212(3A) because the notice had been served in the deceased's individual name and the family bona fide believed it did not concern the Hindu undivided family. That mistaken but reasonable belief constituted reasonable cause for the default, so the penalty was cancelled.

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Issues: Whether penalty under section 273(c) of the Income-tax Act, 1961 was leviable for failure to file a revised estimate of advance tax under section 212(3A) when the advance-tax notice had been received in the deceased's individual name and the family believed it did not relate to the Hindu undivided family.

Analysis: The notice of advance tax had been served during the deceased's lifetime in his individual capacity, and after his death the family members acted under a bona fide belief that the notice was personal to him and not to the Hindu undivided family. This constituted reasonable cause for not filing the estimate required under section 212(3A).

Conclusion: Penalty under section 273(c) was not sustainable and was cancelled.

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