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The High Court of Kerala ruled that the Inspecting Assistant Commissioner had jurisdiction to impose the penalty under section 271(1)(c) in a case where penalty proceedings were initiated before the amendment by the Taxation Laws (Amendment) Act, 1975. The Tribunal's view that the date of filing the return was the material date for determining the authority's competence was deemed incorrect. The court held that the authority's competence should be determined with reference to the law in force on the date of initiation of the penalty proceedings.
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