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    <title>1979 (6) TMI 70 - ITAT GAUHATI</title>
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    <description>A finding that an assessee was prevented by reasonable cause from filing wealth-tax returns on time is a finding of fact, not a question of law, where it rests on the record and the surrounding circumstances. The Tribunal cancelled the penalties after concluding that there was no conscious default and that the explanation of ignorance of the filing obligation was supported by the evidence. Because the dispute challenged only that factual appreciation, no referable question of law arose and the reference applications were not maintainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=65725</link>
      <description>A finding that an assessee was prevented by reasonable cause from filing wealth-tax returns on time is a finding of fact, not a question of law, where it rests on the record and the surrounding circumstances. The Tribunal cancelled the penalties after concluding that there was no conscious default and that the explanation of ignorance of the filing obligation was supported by the evidence. Because the dispute challenged only that factual appreciation, no referable question of law arose and the reference applications were not maintainable.</description>
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