Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Section 273B provides that penalty for belated furnishing of a tax audit report under section 271B is not automatic where the taxpayer establishes reasonable cause. The explanation must be considered judicially to determine whether the default occurred without reasonable cause. The notes identify prior auditor negligence and a consequent change of auditor as reasonable cause where accounts were maintained, the audit was obtained, and the report was furnished before assessment concluded. A technical and venial lapse, without deliberate or wilful default or revenue loss, supports deletion of the penalty.
Section 273B provides that penalty for belated furnishing of a tax audit report under section 271B is not automatic where the taxpayer establishes reasonable cause. The explanation must be considered judicially to determine whether the default occurred without reasonable cause. The notes identify prior auditor negligence and a consequent change of auditor as reasonable cause where accounts were maintained, the audit was obtained, and the report was furnished before assessment concluded. A technical and venial lapse, without deliberate or wilful default or revenue loss, supports deletion of the penalty.
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