Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
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