https://www.taxtmi.com/highlights?id=97254 Penalty under 271(1)(c) was held unsustainable where the assessee filed the tax audit and disclosed financial statements timely, offered the entire income voluntarily after a section 148 notice which was accepted without additions, and discharged tax liability before completion of assessment; these facts supported negligence or inadvertence rather than an intent to conceal, so reasonable cause for non-filing under section 139(1) was established and the deeming fiction in Explanation 3 could not be invoked mechanically. Penalty initiation lacked linkage to any specific concealment or inaccurate particular. en-us Fri, 27 Feb 2026 13:23:10 +0530 Fri, 27 Feb 2026 13:23:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97254 Penalty under 271(1)(c) was held unsustainable where the assessee filed the tax audit and disclosed financial statements timely, offered the entire income voluntarily after a section 148 notice which was accepted without additions, and discharged tax liability before completion of assessment; these facts supported negligence or inadvertence rather than an intent to conceal, so reasonable cause for non-filing under section 139(1) was established and the deeming fiction in Explanation 3 could not be invoked mechanically. Penalty initiation lacked linkage to any specific concealment or inaccurate particular. Highlights Income Tax Fri, 27 Feb 2026 13:23:10 +0530 https://www.taxtmi.com/highlights?id=97254