https://www.taxtmi.com/caselaws?id=27950 Penalty under section 271(1)(a) was attracted where an assessment initially made on a protective basis had, in substance, become a substantive assessment because no other person was assessed on that income. The court also found that the assessee failed to establish reasonable cause for the delay in filing the return, which supported the levy of penalty. The first referred question was not pressed and remained unanswered, while the surviving issue was decided against the assessee and in favour of the Department. en-us Mon, 12 Mar 1984 00:00:00 +0530 Wed, 17 Feb 2010 10:41:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27950 Penalty under section 271(1)(a) was attracted where an assessment initially made on a protective basis had, in substance, become a substantive assessment because no other person was assessed on that income. The court also found that the assessee failed to establish reasonable cause for the delay in filing the return, which supported the levy of penalty. The first referred question was not pressed and remained unanswered, while the surviving issue was decided against the assessee and in favour of the Department. Case-Laws Income Tax Mon, 12 Mar 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27950