https://www.taxtmi.com/caselaws?id=21055 Section 271(2) creates a statutory fiction that, for penalty purposes, a defaulting registered firm must be treated as an unregistered firm. Applied to penalty for failure to furnish the return within time without reasonable cause, the penalty is therefore computed on the basis prescribed for an unregistered firm, after giving effect to the statutory adjustment. The default was established and the departmental computation was upheld. The separate challenge that the penalty was excessive was not examined because it had not been raised before the appellate tribunal and did not arise from the reference. en-us Fri, 17 Apr 1992 00:00:00 +0530 Thu, 19 Nov 2009 17:12:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21055 Section 271(2) creates a statutory fiction that, for penalty purposes, a defaulting registered firm must be treated as an unregistered firm. Applied to penalty for failure to furnish the return within time without reasonable cause, the penalty is therefore computed on the basis prescribed for an unregistered firm, after giving effect to the statutory adjustment. The default was established and the departmental computation was upheld. The separate challenge that the penalty was excessive was not examined because it had not been raised before the appellate tribunal and did not arise from the reference. Case-Laws Income Tax Fri, 17 Apr 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21055