https://www.taxtmi.com/caselaws?id=24820 A Tribunal finding that the assessee had reasonable cause for delayed return filing for part of the period under penalty proceedings was treated as a finding of fact. The Revenue challenged only the correctness of that conclusion, but the High Court held that the existence or absence of reasonable cause does not, by itself, raise a question of law. The precedent relied on by the Revenue was distinguished as factually different and therefore inapplicable. On that basis, no referable question of law arose from the Tribunal's order, and the applications under section 256(2) were rejected. en-us Fri, 01 Jul 1988 00:00:00 +0530 Fri, 22 Jan 2010 15:58:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24820 A Tribunal finding that the assessee had reasonable cause for delayed return filing for part of the period under penalty proceedings was treated as a finding of fact. The Revenue challenged only the correctness of that conclusion, but the High Court held that the existence or absence of reasonable cause does not, by itself, raise a question of law. The precedent relied on by the Revenue was distinguished as factually different and therefore inapplicable. On that basis, no referable question of law arose from the Tribunal's order, and the applications under section 256(2) were rejected. Case-Laws Income Tax Fri, 01 Jul 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24820