Review of Instructions 822 in view of judicial orders.

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..... .I/33/68-IT(Inv) dated 29th September 1969:- While deciding whether return for a particular assessment year is filed voluntarily and in good faith the commissioner should take into consideration all the facts and circumstances of the case including the fact if any that the said return is filed by the assessee after getting a notice u/s.139(2) in respect of another assessment year. 2. Instructi .....

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..... mstances the applicability of sec.271(4A) should be considered separately with reference to the facts in respect of each assessment year. It would not be proper to reject the request for reduction or waiver of penalty in respect of all the assessment years if the section is not applicable in respect of a particular assessment year. Only for the limited purpose of obtaining the boards approval it i .....

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