Held that making a wholistic view of factual panorama of case and circumstances, in which return for year could not be filed within stipulated time, it could be said that there was a reasonable cause, bringing case out of purview of Explanation 3 to 271(1)(c). In the absence of any addition or disallowance in determination of total income by the Assessing Officer. [ AY. 2012-13)
Association of Oral Maxillofacial Surgeons of India v. ITO (2023) 225 TTJ 740 / 156 taxmann.com 332 (Pune)(Trib)
S. 271(1)(c) : Penalty-Concealment-No addition to the returned income-Making a wholistic view of factual panorama of case and circumstances, in which return for year could not be filed within stipulated time, it could be said that there was a reasonable cause, bringing case out of purview of Explanation 3 to 271(1)(c).[ S. 11, 12A, 12AA, 153]