| Case ID |
ea92b2af-4482-415e-9cfb-f95991efefa6 |
| Body |
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| Case Number |
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| Decision Date |
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| Hearing Date |
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| Decision |
The Tribunal held that the non-filing of an estimate under section 212(3A) by the firm constituted a reasonable cause within the meaning of section 273(c) for the non-filing of an estimate under section 212(3A) by the assessee-partner. The court affirmed this ruling, referencing the precedent set in CIT v. Smt. Parvati Devi [1983] 141 ITR 738. Consequently, the reference was answered in favor of the assessee and against the Revenue, indicating that the Tribunal's decision was correct and justified. |
| Summary |
This case revolves around the interpretation of sections 273 and 212(3A) of the Income-tax Act, 1961, concerning penalties for non-filing of tax estimates. The Punjab and Haryana High Court examined whether the Tribunal's decision to recognize the non-filing of an estimate by a firm as a reasonable cause for the partner's non-filing was valid. The case drew from the precedent established in CIT v. Smt. Parvati Devi, reinforcing the notion that reasonable causes must be acknowledged in tax law. This ruling emphasizes the importance of understanding statutory requirements and the implications of non-compliance. The case highlights the balance between regulatory compliance and equitable considerations in taxation, providing essential insights for tax practitioners and legal professionals in navigating similar disputes. Legal representatives and advocates involved in tax law should take note of this decision as it may influence future interpretations of tax compliance and penalties. |
| Court |
Punjab and Haryana High Court
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| Entities Involved |
Not available
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| Judges |
Gokal Chand Mital,
S.S. Sodhi
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| Lawyers |
L.K. Sood,
Bhagirath Dass,
Ramesh Kumar
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| Petitioners |
Commissioner of Income Tax
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| Respondents |
Rajinder Kumar
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| Citations |
1989 SLD 2635,
(1989) 179 ITR 82
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| Other Citations |
CIT v. Smt. Parvati Devi [1983] 141 ITR 738 (P&H)
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| Laws Involved |
Income-tax Act, 1961
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| Sections |
273,
212(3A)
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