Penalty Not Automatic: ITAT Cancels 272A(2)(e) Fine Due to COVID and Communication Gaps

Shankar Math Vs ITO(E) (ITAT Delhi) Mandatory Penalty Under 272A(2)(e) Not Automatic: Communication Gap & Covid Count as Reasonable Cause -ITAT Gives Relief to Trust Assessee, a charitable trust, was levied penalty of ₹2,42,300 u/s 272A(2)(e) @ ₹100 per day for 2,423 days’ delay in filing return, which CIT(A)/NFAC upheld. Before Tribunal, Revenue argued that Assessee failed to show any reasonable cause. Tribunal, however, accepted that for a trust, communication lapses between management & auditor cannot be ruled out, particularly since penalty proceedings began during the Covid-...