Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Where registered sale deeds were cancelled and consideration reversed but those documents were not placed before the assessing officer during assessment proceedings, cancelled transactions were treated as not giving rise to taxable income. The document stresses that evidence of cancellation and reversal, when first produced only before the court, defeats assessment orders premised on the original transactions. The assessing officer's failure to consider cancellation and reversal rendered impugned assessment orders unsustainable, resulting in quashing and setting aside of those orders and disposal in light of the cited precedent.
Where registered sale deeds were cancelled and consideration reversed but those documents were not placed before the assessing officer during assessment proceedings, cancelled transactions were treated as not giving rise to taxable income. The document stresses that evidence of cancellation and reversal, when first produced only before the court, defeats assessment orders premised on the original transactions. The assessing officer's failure to consider cancellation and reversal rendered impugned assessment orders unsustainable, resulting in quashing and setting aside of those orders and disposal in light of the cited precedent.
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