Assessee cannot claim to be under reasonable belief of Income Exemption after paying Tax on the same for 40 Years

While confirming the penalty levied on the assessee/Trust under Section 273(2)(a) as well as under Section 140A(3) of the Income Tax Act 1961, the learned ITAT has thoroughly examined the matter and concluded that as for last forty years, income of the assessee/Trust was held to be taxable by several decisions rendered by the Tribunal which were not upset till then, there is no scope for holding that the assessee/Trust was prevented by a reasonable cause from filing its estimate of advance tax and in not paying the tax on the basis of self assessment. The learned ITAT further held that there i...