Whether reasonable cause is to be stated before AO or it is to be proved?
Mere statement about reasonable cause is not sufficient. You must prove the facts stated before AO while pleading existence of reasonable cause. Existence of reasonable cause is to be proved. 15.1 Penalty is inevitable if reasonable cause not established ACIT vs Jabalpur Hospital & Research Centre (p) Ltd (2006) 103 TTJ (jab Trib) 536 15.2 Necessity for the purpose of businseness not proved and loan not recorded in books.Penalty leviable. Thennamal Chajjer Vs.
