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2017 (10) TMI 1499 - ITAT BANGALOREPenalty u/s 271F - failure to file the return of income on or before the end of the relevant assessment year - Admission of additional evidence - existence of reasonable cause under Section 273B - HELD THAT:- Additional evidence now sought to be filed by the assessee before the Tribunal are necessary and required proper adjudication of the issues involved in the appeal. These evidence, according to the assessee, show that the assessee was dependent on its holding company for day to day affairs and for financial support including payment of self-assessment tax. The additional evidence is therefore admitted for consideration. Since the revenue authorities did not have an opportunity to examine the additional evidence now admitted by the Tribunal, we deem it proper to set aside the order of the CIT (Appeals) and remand the question of the existence of reasonable cause under Section 273B of the Act for fresh consideration by the Assessing Officer in the light of the additional evidence now admitted by the Tribunal. The Assessing Officer shall afford an opportunity of being heard to the assessee before deciding the issue. Appeal is allowed for statistical purposes.
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