9911796707
TMI Blog1980 (4) TMI 160X X X X Extracts X X X X X X X X Extracts X X X X ..... 9th Sept., 76. Thus there was a delay of 36 months in filing the return. The ITO started penalty proceedings. In response of service of show cause notice, the assessee, vide written reply contended that due to omission or default on the part of the assessee's counsel the return could not be filed. In support of this contention the assessee also filed an affidavit. After filing such reply the ITO r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alongwith the return of income of the firm to his counsel on 15th Aug., 1973 for filing the same but it appears that the counsel did not file the same under some mistake. It was also submitted that at the time relevant the assessee was also not well. Thus it was contended that there were reasonable causes which prevented the assessee from filing the return of income in time. 5. The learned depar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e relevant period he was not quite well. The learned ITO did issue a notice to the assessee to file confirmation from the previous counsel within three days. According to the learned counsel the time given by the ITO was quite insufficient. Even the learned AAC did not give specific opportunity to file confirmation from the earlier counsel. From the order sheet it is clear that the authorities bel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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