TMI Blog1980 (4) TMI 166X X X X Extracts X X X X X X X X Extracts X X X X ..... 1973 but it was filed on 27th Oct., 1978. Thus there was delay of 30 Months in filing the return. The learned ITO started penalty proceedings under s. 271(1)(a) of the Act. In penalty proceedings, inter alia, it was contended that Shri Ladharam was one of the partners in the firms, M/s. Rooplal Danchand, Paris Wine Store and Paris General Store. He could not receive share income from all the firms ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er submitted that the delay was not deliberate. 5. The ld. Deptl. Rep. supported the order of the AAC and contended that the assessee produced no evidence to show that on account of reasonable causes the assessee failed to file the return. 6. In our opinion, the contention of the assessee is quite correct. The assessee gave detailed explanation before the authorities below. The assessee is one ..... X X X X Extracts X X X X X X X X Extracts X X X X
|