https://www.taxtmi.com/caselaws?id=19792 Penalty for delayed filing of income-tax returns is a civil consequence for statutory default, so the constitutional protection against double jeopardy does not exclude overlapping periods of delay across different assessment years. Each year's failure to furnish a return in time is an independent default, even where the delay period overlaps. The Tribunal's finding that there was reasonable cause for the delay up to 12 February 1980 and for the later period was based on evidence and treated as a finding of fact. In reference jurisdiction, such factual findings are ordinarily not open to reassessment unless a distinct question of law arises. en-us Mon, 26 Jul 1993 00:00:00 +0530 Mon, 09 Nov 2009 17:17:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19792 Penalty for delayed filing of income-tax returns is a civil consequence for statutory default, so the constitutional protection against double jeopardy does not exclude overlapping periods of delay across different assessment years. Each year's failure to furnish a return in time is an independent default, even where the delay period overlaps. The Tribunal's finding that there was reasonable cause for the delay up to 12 February 1980 and for the later period was based on evidence and treated as a finding of fact. In reference jurisdiction, such factual findings are ordinarily not open to reassessment unless a distinct question of law arises. Case-Laws Income Tax Mon, 26 Jul 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19792