Penalty levied u/s 272A(1)(d) for non-compliance with ...

COVID-19 restrictions considered reasonable cause for non-compliance with documentary evidence requirements, exculpating assessee from penalty.

Case Laws     Income Tax

September 7, 2024

Penalty levied u/s 272A(1)(d) for non-compliance with documentary evidence requirements was challenged by the assessee, citing COVID-19 restrictions as a reasonable cause. The Tribunal held that in the prevailing pandemic situation, it was unreasonable for tax authorities to expect strict compliance from the assessee. The failure to furnish information/documents during the reassessment proceedings was attributable to the subsistence of COVID-19, which prevented effective compliance. Demanding documentary evidence to prove the reasonable cause of COVID-19 restrictions suggested non-application of mind by the authorities. The Tribunal relied on the Supreme Court's recognition of COVID-19 restrictions and held that the pandemic situation, along with the apex court's order, formed a reasonable cause u/s 273B, exculpating the assessee from penalty u/s 272A(1)(d). Consequently, the penalty order was set aside as unwarranted.

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