1979 (8) TMI 7

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....sed by the Commissioner of Income-tax dismissing revisions, which in turn were directed against the appellate orders rejecting the plea that the petitioner-assessee was not liable to penalty under s. 271(1)(a) for delay in filing the return. For the assessment year 1967-68, admittedly, the return was filed four months late while for the assessment year 1968-69, it was filed 22 months late. The ....

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....t and no evidence has been led to establish that fact. When the delay is admitted and the default has taken place under cl. (a) of s. 271 (1), the penalty is imposable if the assessee had delayed in filing the return without reasonable cause. He has prima facie to satisfy the authorities that he had reasonable cause for the delay in filing the return. Under cl. (a) the penalty is not imposed for a....