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Petitioner failed to submit tax audit report timely. Assessing Officer (AO) concluded late filing showed mala fide intent to evade tax. Court held AO's conclusion unsustainable as petitioner's disclosed income and tax liability were accepted. AO's finding that petitioner fabricated medical reasons was also unsustainable given doctor's prescription. Order quashed for speculative findings contrary to facts. Matter remanded for reconsideration after providing reasonable opportunity to petitioner, considering all material facts, applicable provisions like Section 273B, and passing reasoned order.
Petitioner failed to submit tax audit report timely. Assessing Officer (AO) concluded late filing showed mala fide intent to evade tax. Court held AO's conclusion unsustainable as petitioner's disclosed income and tax liability were accepted. AO's finding that petitioner fabricated medical reasons was also unsustainable given doctor's prescription. Order quashed for speculative findings contrary to facts. Matter remanded for reconsideration after providing reasonable opportunity to petitioner, considering all material facts, applicable provisions like Section 273B, and passing reasoned order.
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