1979 (7) TMI 133

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....e cancellation by the AAC of penalties imposed by the WTO for failure to furnish the WT returns in time without reasonable cause. 2. The facts are all stated in the impugned appellate order. The Deptl. Rep. submitted before us that the findings of the AAC which lead to the cancellation are contrary to facts and opposed to law. According to the WTO who imposed penalties and the AAC who cancelled....

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....Representative is naturally in difficulty to say that there is no reasonable cause upto 19th Aug., 1970. This aspect has of course been noticed and commented upon adversely to the Department by the AAC in these WT appeals. So the Department has raised a tricky ground which requires some discussion. The AAC has not dealt with or if dealt with not satisfactorily dealt with that aspect. The ground ra....

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....s as follows: "......Now I came to understand that I am liable to IT and WT in respect of asst. yrs. 1962-63 and onwards. All my income consists of the interest on the pronotes which have been executed by land purchasers. I am filing particulars of my income and WT for the asst. yrs. 1962-63 onwards before 5th ITO, City Circle-I, Madras who I understand is having jurisdiction over my case.......