TMI Blog2022 (6) TMI 548X X X X Extracts X X X X X X X X Extracts X X X X ..... enclosed and submitted as evidence - also explained that practically it was difficult to get an experienced accountant within the short period of time in a place like Akkalkot, Dist. Solapur. Therefore, the entire events and circumstances were beyond the control of the assessee and he was helpless and for such reasons delay occurred which was never deliberate nor intentional. The ld. CIT(A) howeve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pital. The ld. CIT(A) should have considered all these facts in its proper perspective. Section 273B of the Act provides that the penalty u/s 271B need not be imposed if there is a reasonable cause for the said failure. In our considered view, the assessee in this case through documentary evidence has explained the reasonable cause and accordingly we set aside the order of the CIT(A) and direct th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ietary concern under the name and style Swaminath Nilkanth Patil at Akkalkot. That on perusal of the grounds of appeal filed by the assessee, the only grievance in this appeal is imposition of penalty u/s 271B of the Income-tax Act, 1961 (hereinafter referred to as the Act ). The assessee had e-filed return of income on 28-01-2015 declaring total income of Rs. 6,33,380/-. The case was selected ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e. It was also explained that practically it was difficult to get an experienced accountant within the short period of time in a place like Akkalkot, Dist. Solapur. Therefore, the entire events and circumstances were beyond the control of the assessee and he was helpless and for such reasons delay occurred which was never deliberate nor intentional. The ld. CIT(A) however, as per the reasons appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) should have considered all these facts in its proper perspective. Section 273B of the Act provides that the penalty u/s 271B need not be imposed if there is a reasonable cause for the said failure. In our considered view, the assessee in this case through documentary evidence has explained the reasonable cause and accordingly we set aside the order of the CIT(A) and direct the A.O to delete the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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