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TMI Blog1994 (4) TMI 28X X X X Extracts X X X X X X X X Extracts X X X X ..... above assessment years at Rs. 22,450, Rs. 22,450, Rs. 10,300, Rs. 10,300,Rs. 10,300, Rs. 16,300 and Rs. 18,500 and made a demand of Rs. 4,022, Rs. 3,338, Rs. 386, Rs. 606, Rs. 606, Rs. 606, Rs. 1,028 and Rs. 935, respectively. For the above assessment years, the Income-tax Officer levied inter est under section 139(8) of the Act at Rs. 3,410, Rs. 2,516, Rs. 210, Rs. 360, Rs. 312, Rs. 240, Rs. 280 and Rs. 140 ; under section 217 of the Act at Rs. 2,820, Rs. 2,126, Rs. 260, Rs. 426, Rs. 336, Rs. 252, Rs. 320 and Rs. 180 and penalty under section 271(1)(a) at Rs. 2,010, Rs. 1,670, Rs. 200, Rs. 300, Rs. 300, Rs. 300, Rs. 540 and Rs. 280 under section 273(b) and Rs. 300 and Rs. 250 respectively. The total interest payable under section 139(8) wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terest and penalties levied on the petitioner. I am unable to accept the above contention of learned counsel for the petitioner. Section 273A of the Act contemplates a full disclosure by the assessee of his income voluntarily and in good faith before the issue of notice under section 139(2) of the Act. It is seen from the reply dated July 9, 1981, submitted by the petitioner before the second respondent to the notice of hearing under section 273A of the Act, that the case of the petitioner before the second respondent is that the petition under section 273A was filed on June 25, 1975, making full disclosure of the total income of the assessee, and that the notices under sections 139 and 148 were issued to the petitioner on January 30, 1976, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 273A of the Act. The letter dated June 25, 1975, reads thus : " I am a resident in the above address and have acquired the following properties. I am not assessed to income-tax so far. I am taking steps to engage an auditor to prepare my returns of income taking into account the acquisitions made by me so far. I am mainly an agriculturist and am completely ignorant of the taxation laws. Hence I request that all the benefits contemplated under section 271(4)(a) of the Act may kindly be extended to me. I may also be given two months ' time to file the returns of income. List of acquisitions : ---------------------------------------------------------------------------------------------------------------------------------------- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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