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TMI Blog1977 (7) TMI 76X X X X Extracts X X X X X X X X Extracts X X X X ..... of the penalty is levied by the WTO under s. 18(1)(a) of the Act in the sums of Rs. 1,422, Rs. 2,323 and Rs. 2,647 for the three assessment years respectively. The brief facts which led to these penalties were as follows. (The facts are extracted from the statement filed for the assessee, the facts stated therein not being in controversy.) Asst. yr. 1966-67 1967-68 1968 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ied; and for the period of default beyond 31st March, 1969 the penalty provisions, as they were amended effective from 1st April, 1969, would apply. It is common ground that this was how the WTO proceeded in levying the impugned penalties. The AAC did not favour this approach. Following the decision of the Madras High Court in Muthukumaraswamy Mudalier s (1975 CTR (Mad) 67 : 98 ITR 640 (Mad)) case ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h Court in 106 ITR 965 and also by thePunjaband Haryana High Court in 108 ITR 86. Thus, the submission for the assessee was that the approach of the AAC being supported by the strong direct authority of three High Courts, did not call for interference. 4. We think that the submissions for the assessee have great force. In the case of Suresh Seth vs. CWT 108 ITR 86 (P H) thePunjaband Haryana has ..... X X X X Extracts X X X X X X X X Extracts X X X X
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