TMI Blog1994 (1) TMI 41X X X X Extracts X X X X X X X X Extracts X X X X ..... e been referred by the Appellate Tribunal: "(1) Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding and had valid materials to hold that the assessee was prevented by reasonable cause from furnishing the return of income in time and, therefore, there was no need to levy penalty under section 271(1)(a) and the penalty of Rs. 66,120 levied deserv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 271(1)(a) and under section 273(c). The assessee contended that since he was an illiterate and had entrusted the matter to his brother-in-law who was actually carrying on the business, he was under the belief that he was under no legal obligation to file the return or the estimate. No doubt, this explanation was given only before the Appellate Assistant Commissioner. But the Appellate Tribu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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