Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Pandemic-related disruption, a plausible bona fide belief about return-filing obligations, and subsequent participation in assessment proceedings are identified as reasonable cause for non-compliance with statutory notices by an educational trust. The note states that mere non-compliance, without independent material showing deliberate or wilful disregard, does not justify penalty. It further describes penalty provisions as quasi-criminal and inapplicable to technical or venial defaults where surrounding circumstances establish reasonable cause. On these grounds, the penalty for non-compliance with statutory notices was described as unsustainable and deleted.
Pandemic-related disruption, a plausible bona fide belief about return-filing obligations, and subsequent participation in assessment proceedings are identified as reasonable cause for non-compliance with statutory notices by an educational trust. The note states that mere non-compliance, without independent material showing deliberate or wilful disregard, does not justify penalty. It further describes penalty provisions as quasi-criminal and inapplicable to technical or venial defaults where surrounding circumstances establish reasonable cause. On these grounds, the penalty for non-compliance with statutory notices was described as unsustainable and deleted.
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