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TMI Blog1995 (9) TMI 52X X X X Extracts X X X X X X X X Extracts X X X X ..... the following question stated to be of law and to arise out of its order dated May 10, 1979, passed in W. T. A. No. 756/(Delhi) of 1977-78 for the assessment year 1967-68 for the opinion of this court : " Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the penalty should be worked out on the basis of the law as it existed on the date when ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate Tribunal held that the penalty was leviable according to the law as it was in force on the date when the return was due. This controversy has since been settled by the decisions of the Supreme Court in Maya Rani Punj v. CIT [1986] 157 ITR 330 and CWT v. P. N. Banerjee [1991] 192 ITR 399. In Maya Rani Punj's case [1986] 157 ITR 330 (SC), the controversy was of a similar nature, but arising un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s. The same view was taken by this court in CWT v. Smt. Brij Rani [1993] 201 ITR 307 in which dealing with the assessment years 1967-68 and 1968-69, this court held that the penalties under section 18(1)(a)(i) of the Wealth-tax Act were to be levied for the period of delay prior to April 1, 1969, in terms of the prescribed rates with reference to the unamended section 18 of the Act as it stood pri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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