Penalty Limitations and Reasonable Cause: Navigating the Nuances of Tax Penalties

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ative bank and the Income Tax Officer (ITO), the Tribunal addressed two critical legal issues: (1) the applicability of the limitation period for imposing penalties under Sections 271D and 271E of the Income Tax Act, 1961 (the Act), and (2) the concept of 'reasonable cause' under Section 273B of the Act. This in-depth analysis explores the Tribunal's reasoning and implications of its d....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ause: The Tribunal considered the concept of 'reasonable cause' under Section 273B. It held that the appellant, functioning effectively as a bank (despite being a co-operative society), had a reasonable cause for the contravention, given its long-standing operational history and the nature of its business. III. Legal Analysis * Interpreting Section 275(1)(c): * The Tribunal's in....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tation could raise concerns about the potential for entities to circumvent regulatory requirements, especially those imposed by the Banking Regulation Act and the Reserve Bank of India. * Broader Implications: * The decision provides clarity on the interpretation of procedural aspects of tax penalty provisions, which can be critical for taxpayers and tax authorities. * The Tribunal's p....