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    <title>1977 (12) TMI 39 - ITAT AHMEDABAD-A</title>
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    <description>Penalty under section 271(1)(a) for late filing was held unsustainable where the assessee had entrusted tax compliance to a regular income-tax practitioner and the return was not filed because the practitioner failed to act. Although the return was neither filed within time under section 139(1) nor in response to notice under section 148, and assessment proceeded under section 144, the Tribunal treated the assessee&#039;s conduct as prudent and reasonable. On those facts, the default was not characterised as wilful neglect, gross neglect, or a flagrant violation of law, and reasonable cause was accepted.</description>
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    <pubDate>Fri, 23 Dec 1977 00:00:00 +0530</pubDate>
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      <title>1977 (12) TMI 39 - ITAT AHMEDABAD-A</title>
      <link>https://www.taxtmi.com/caselaws?id=55391</link>
      <description>Penalty under section 271(1)(a) for late filing was held unsustainable where the assessee had entrusted tax compliance to a regular income-tax practitioner and the return was not filed because the practitioner failed to act. Although the return was neither filed within time under section 139(1) nor in response to notice under section 148, and assessment proceeded under section 144, the Tribunal treated the assessee&#039;s conduct as prudent and reasonable. On those facts, the default was not characterised as wilful neglect, gross neglect, or a flagrant violation of law, and reasonable cause was accepted.</description>
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      <pubDate>Fri, 23 Dec 1977 00:00:00 +0530</pubDate>
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