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Facts
The assessee, a retired employee, failed to respond to notices under section 142(1) and consequently faced a penalty under section 272A(1)(d) and an ex-parte assessment under section 144. The assessee contended that the non-compliance was due to ignorance of e-proceedings and miscommunication, not deliberate intent.
Held
The Tribunal found that the Commissioner of Income-tax (Appeals) failed to appreciate the assessee's stated reasons for non-compliance. It was held that the non-compliance was not deliberate and that the assessee had reasonable cause as per section 273B.
Key Issues
Whether penalty under section 272A(1)(d) is sustainable when non-compliance with notices under section 142(1) is due to ignorance and reasonable cause.
Sections Cited
272A(1)(d), 142(1), 144, 273B
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Before: SHRI ANIKESH BANERJEE & SHRI PRABHASH SHANKAR
PER PRABHASH SHANKAR [A.M.] :- The present appeal arising from the appellate order dated 04.08.2025 is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)