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The ITAT allowed the appeal and set aside the penalty under s. 272A(1)(d), finding that the assessee failed to comply with two notices issued under s. 142(1) due to an inadvertent lapse caused by the authorised representative being temporarily unavailable. The Tribunal held the explanation to be bona fide, not indicative of willful default, defiance, or contumacious conduct. Having regard to the assessee's overall conduct and reliance on established precedent recognizing reasonable cause as a defence to such penalties, the Tribunal concluded that imposition of penalty was unjustified and remitted relief to the assessee.
The ITAT allowed the appeal and set aside the penalty under s. 272A(1)(d), finding that the assessee failed to comply with two notices issued under s. 142(1) due to an inadvertent lapse caused by the authorised representative being temporarily unavailable. The Tribunal held the explanation to be bona fide, not indicative of willful default, defiance, or contumacious conduct. Having regard to the assessee's overall conduct and reliance on established precedent recognizing reasonable cause as a defence to such penalties, the Tribunal concluded that imposition of penalty was unjustified and remitted relief to the assessee.
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