Interim judicial restraint preventing treatment of foreign-leg...

Interim judicial restraint preventing treatment of foreign-leg Leave Fare Concession reimbursements as income for tax-deduction purposes meant the deductor did not breach an enforceable deduction obligation; tax-default demands and consequential interest were therefore deleted. Subsequent substantive taxability could not retrospectively turn compliance with the subsisting direction into a default. Compliance with that direction also constituted statutory reasonable cause, supporting deletion of non-deduction penalties. Institutional delays in penalty appeals were condoned where multi-level approvals, lost portal access after personnel changes, and access resetting showed sufficient cause without deliberate delay, mala fides, benefit to the deductor, or prejudice to revenue.