https://www.taxtmi.com/caselaws?id=765695 A challenge under section 260A based only on the Tribunal's factual finding of reasonable cause did not raise a substantial question of law, because such a challenge must show a legal issue or perversity in the finding. On the penalty issue, section 271C was held inapplicable where the assessee established reasonable cause under section 273B through bona fide legal advice, supporting professional opinions, and the pending advance-ruling process. Those circumstances were accepted as credible and showed the default was not wilful. The penalty relief was therefore upheld and the Revenue's appeal was rejected. en-us Mon, 03 Feb 2025 00:00:00 +0530 Tue, 10 Jun 2025 14:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765695 A challenge under section 260A based only on the Tribunal's factual finding of reasonable cause did not raise a substantial question of law, because such a challenge must show a legal issue or perversity in the finding. On the penalty issue, section 271C was held inapplicable where the assessee established reasonable cause under section 273B through bona fide legal advice, supporting professional opinions, and the pending advance-ruling process. Those circumstances were accepted as credible and showed the default was not wilful. The penalty relief was therefore upheld and the Revenue's appeal was rejected. Case-Laws Income Tax Mon, 03 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765695