9911796707
TMI Blog1972 (11) TMI 4X X X X Extracts X X X X X X X X Extracts X X X X ..... ing penalty under section 271(1) – held that provision for levy of penalty as well as interest for delayed filing of return cannot be said to be offending any constitutional provision X X X X Extracts X X X X X X X X Extracts X X X X ..... tion as the liability for penalty and the quantum thereof have to depend on a mere fortuitous circumstance of the assessment having been completed before or after the new Act came into force and the classification made between assessees whose assessments have been completed before April 1, 1962, and those whose assessments have not been completed by that date in the matter of levy of penalty is di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to raise additional grounds. The additional grounds sought to be raised in these three petitions relate to the interpretation of section 271(1)(a)(i). According to the petitioner on a proper interpretation of section 271(1)(a)(i) the orders levying penalty in this case and particularly the quantum thereof need modification. But, if the attack is mainly on the quantum of penalty levied, the proper ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal in the third year. It is stated by the learned counsel for the petitioner that the time for filing appeals in all the three cases had already expired. But, it is open to the petitioner to file appeals challenging the penalty orders for all the three years along with applications for excusing the delay on the ground that the appeals could not be filed in time as he has been pursuing his reme ..... X X X X Extracts X X X X X X X X Extracts X X X X
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