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Issues:
1. Taxability of interest received on enhanced compensation. 2. Validity of assessment based on the second return filed beyond the limitation period. 3. Imposition of penalty under section 271(1)(a) for late filing of return. 4. Imposition of penalty under section 273(2)(b) for failure to submit an estimate of advance tax. Analysis: 1. Taxability of interest received on enhanced compensation: The case involved appeals related to the assessment year 1980-81 concerning the taxability of interest received by the assessee on enhanced compensation for acquired land. The dispute arose when the Assessing Officer treated the entire interest amount as assessable in the year under appeal, while the CIT(A) held that only a portion was taxable. The Tribunal referred to previous decisions and the legal principle of accrual basis for interest on enhanced compensation. The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision based on the legal view established by the Supreme Court in Rama Bai's case. 2. Validity of assessment based on the second return filed beyond the limitation period: The legal issue raised by the counsel was the validity of the assessment made on the basis of a second return filed beyond the limitation period, despite the initial assessment being cancelled. The counsel argued that the assessment should have been based on the first return filed within the prescribed time limit. However, since the Revenue's appeal was dismissed, the assessee's appeal on this matter was also dismissed by the Tribunal. 3. Imposition of penalty under section 271(1)(a) for late filing of return: The penalty was imposed on the assessee for late filing of the return, which was subsequently challenged before the CIT(A). The counsel contended that the penalty was not justified as the assessee had filed multiple extension applications, constituting sufficient cause for the delay. Citing relevant case law, the Tribunal found that the penalty was not leviable due to the circumstances of the case, especially considering that the Assessing Officer did not reject any of the extension applications filed by the assessee. 4. Imposition of penalty under section 273(2)(b) for failure to submit an estimate of advance tax: The penalty was imposed on the assessee for not submitting an estimate of advance tax, which was upheld by the first appellate authority but subject to re-computation after considering relief in the quantum appeal. The Tribunal, after considering the income shown in the return and the debatable nature of the interest amount, concluded that no penalty should be levied under section 273(2)(b). The Tribunal deleted the penalty, stating that the income shown by the assessee did not warrant the penalty imposition. In conclusion, the Tribunal dismissed the Revenue's appeals and allowed the assessee's appeals in the penalty matters, emphasizing the legal principles and factual circumstances in each issue.
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