https://www.taxtmi.com/caselaws?id=13966 The assessee's belated return, filed with self-assessment tax, was supported by an explanation that the income was first treated as capital gains from transfer of capital assets but, on professional advice, was later understood to be business income, making the earlier exemption claim untenable. That explanation was accepted by the appellate authority and the Tribunal on the same factual basis. The High Court treated the sufficiency of the explanation as a question of fact and found that no independent question of law, much less a substantial question of law under section 260A, arose for consideration. en-us Mon, 03 Jul 2000 00:00:00 +0530 Mon, 06 Jul 2009 16:09:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13966 The assessee's belated return, filed with self-assessment tax, was supported by an explanation that the income was first treated as capital gains from transfer of capital assets but, on professional advice, was later understood to be business income, making the earlier exemption claim untenable. That explanation was accepted by the appellate authority and the Tribunal on the same factual basis. The High Court treated the sufficiency of the explanation as a question of fact and found that no independent question of law, much less a substantial question of law under section 260A, arose for consideration. Case-Laws Income Tax Mon, 03 Jul 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13966