https://www.taxtmi.com/caselaws?id=28031 For penalty under section 271(1)(a) of the Income-tax Act, 1961, assessed tax must be computed on the statutory basis prescribed by the Act, and tax paid under section 23B of the Indian Income-tax Act, 1922 cannot be deducted in that computation. The absence of reasonable cause for delay in filing the return attracts penalty, and mens rea is not a necessary ingredient for liability under the provision. The commentary therefore states that penalty remains exigible where the assessee cannot show reasonable cause, even if contumacious conduct is not established. en-us Wed, 01 Feb 1984 00:00:00 +0530 Wed, 17 Feb 2010 14:23:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28031 For penalty under section 271(1)(a) of the Income-tax Act, 1961, assessed tax must be computed on the statutory basis prescribed by the Act, and tax paid under section 23B of the Indian Income-tax Act, 1922 cannot be deducted in that computation. The absence of reasonable cause for delay in filing the return attracts penalty, and mens rea is not a necessary ingredient for liability under the provision. The commentary therefore states that penalty remains exigible where the assessee cannot show reasonable cause, even if contumacious conduct is not established. Case-Laws Income Tax Wed, 01 Feb 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28031