Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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