Section 271D Penalty Not Valid If Assessee Bonafidely explains Reasonable Cause

Bapujibuwa Nagari Sahakari Pat Sanstha Maryadit VS JCIT (ITAT Pune)

The expression ‘reasonable cause’ has to be considered pragmatically and if the facts of the present case are examined keeping this legislative spirit in mind, we find that there were enough circumstances to show that the assessee company had acquired bona-fide belief that its activities are at par with the bank.

After considering the totality of circumstances, namely, the bona-fide belief of the assessee that

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