TMI Blog1983 (2) TMI 26X X X X Extracts X X X X X X X X Extracts X X X X ..... o as " the Act") The material facts giving rise to this application briefly are as follows: For the assessment year 1971-72, the assessee had to file a return on or before September 30, 1971, but the return was, however, filed on March 22, 1973. The ITO, therefore, initiated penalty proceedings against the assessee under s. 271(1)(a) of the Act. In reply to the show-cause notice, the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee has filed this application praying that the Tribunal should be directed to refer the following question of law to this court for its opinion : " Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the assessee had without reasonable cause failed to furnish the return in time under s. 139 and thus upholding the levy of penalty under s. 271(1)(a) o ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
