TMI Blog2000 (9) TMI 58X X X X Extracts X X X X X X X X Extracts X X X X ..... the Wealth-tax Act, 1957 (in short "the Act"), at the instance of the Revenue by the Income-tax Appellate Tribunal, Delhi Bench "D" (for short "the Tribunal"), and the following questions have been referred for the opinion of this court: "1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the assessee was not liable for penalties under secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... osed penalties for all the four years. The assessee preferred appeals before the first appellate authority, i.e., the Appellate Assistant Commissioner (in short "the AAC"), who deleted the penalties. The order of the Appellate Assistant Commissioner was assailed before the Tribunal by the Revenue. By order dated June 17, 1982, the Tribunal accepted the assessee's plea and directed deletion of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed for extension of time up to 30th of September of each year. The assessee could apply for extension of time even belatedly, i.e., after the expiry of the last dates for filing of the returns and it is for the Revenue to have discussed the extension application and if thought fit and warranted by facts to have rejected these applications. But since these belated applications praying for extension ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her there was a sufficient cause for the delay in filing of the returns is essentially factual. The Tribunal has recorded a finding with reference to materials on record that sufficient cause existed for belated filing of the returns. The finding being factual, which cannot be called to be perverse or unreasonable, in our view no question of law arises. We, therefore, decline to answer the questio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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