https://www.taxtmi.com/caselaws?id=39397 The Tribunal may permit an additional ground of appeal where it raises a pure question of law and is taken at the earliest stage, so no error arises in entertaining it. For penalty for failure to file returns under section 271(1)(a) of the Income-tax Act, 1961, and the corresponding Wealth-tax Act provision, mens rea is not a separate essential ingredient; penalty proceedings are civil and remedial, not criminal prosecution. The decisive inquiry is whether the statutory default without reasonable cause is established, and the department is not required to prove mens rea as such. en-us Tue, 10 Sep 1974 00:00:00 +0530 Fri, 16 Jan 2026 16:35:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39397 The Tribunal may permit an additional ground of appeal where it raises a pure question of law and is taken at the earliest stage, so no error arises in entertaining it. For penalty for failure to file returns under section 271(1)(a) of the Income-tax Act, 1961, and the corresponding Wealth-tax Act provision, mens rea is not a separate essential ingredient; penalty proceedings are civil and remedial, not criminal prosecution. The decisive inquiry is whether the statutory default without reasonable cause is established, and the department is not required to prove mens rea as such. Case-Laws Income Tax Tue, 10 Sep 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39397