9911796707
TMI Blog1984 (1) TMI 177X X X X Extracts X X X X X X X X Extracts X X X X ..... ,121 in the aggregate for the said five years, for the reason that the wealth-tax returns to be voluntarily furnished were furnished late. Fortunately the AAC cancelled these uncalled for impositions. Hence, the Department appeals. 2. The facts are well stated in the orders of the wealth-tax authorities. Therefore, we need not, except to the extent necessary to set out our view point, repeat tho ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... made a separate disclosure u/s 15 (Voluntary Disclosure of Wealth). The AAC found reasonable cause for the failure. That is why the penalties were cancelled. 3. The assessee-respondent submitted before us that there is no need to make a separate disclosure u/s 15 and that s. 14 itself provided absolute immunity form penalty, under the WT Act and that this position is also made clear in the press ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... "said Acts" refer to WT Act also. This is a out any modification. So the assessee become liable to wealth-tax only because of the assets representing the disclosed income. So there is immunity form penalty proceedings for not filing wealth-tax returns. So penalty cannot be levied for failure to file wealth-tax returns. 4. However, we would not like to rest our decision on the immunity alone. Thi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lief is only a reasonable belief and such reasonable belief do constitute reasonable cause for failure to file the wealth-tax returns. So there is reasonable cause also in this case. apart from the reasonable cause on erroneous advice found by the AAC. We also agree with the reasonings and conclusion of the AAC. So, for these reasons, these five Departmental appeals are dismissed. - - TaxTMI - ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
