Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Appellate authority failed to apply independent mind by paraphrasing the adjudicating authority and neglecting the petitioner's explanations and documents on record; the HC found the appellate order uninformed and susceptible to judicial reproach. The court held that the appellate order does not reveal consideration of submissions or file documents and therefore set aside the impugned order and remanded the matter for fresh merits consideration by the appellate authority, directing proper examination of the petitioner's grounds and documents on record.
Appellate authority failed to apply independent mind by paraphrasing the adjudicating authority and neglecting the petitioner's explanations and documents on record; the HC found the appellate order uninformed and susceptible to judicial reproach. The court held that the appellate order does not reveal consideration of submissions or file documents and therefore set aside the impugned order and remanded the matter for fresh merits consideration by the appellate authority, directing proper examination of the petitioner's grounds and documents on record.
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