ITAT says Reasonable Cause defeats Penalty

The Ahmedabad ITAT held that filing a return only pursuant to reassessment proceedings does not, by itself, attract Section 271(1)(c). Explanation 3 to Section 271(1)(c) requires absence of reasonable cause before a taxpayer can be deemed to have concealed income. 

Since the assessee established a bona fide explanation for the original non-filing and the reassessment accepted the returned income without addition, the penalty was deleted.