9911796707
TMI Blog1985 (5) TMI 30X X X X Extracts X X X X X X X X Extracts X X X X ..... lating to the assessment year 1967-68 is as follows: "Whether, on the facts and in the circumstances of the case and on a true interpretation of sections 274(2) and 275, the Tribunal was right in upholding the orders of the Inspecting Assistant Commissioner? " Learned counsel for the assessee contended that, in fact, there were other questions which had been sought in the reference application ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 275 of the Act was amended by the Taxation Laws (Amendment) Act, 1970, with effect from April 1, 1971. The present reference relates to the assessment year 1967-68. However, the assessment was completed on January 29, 1972, after the amendment had been made. The limitation period for passing a penalty order was amended by altering the language of section 275 of the Act. The present section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Such an amendment is substantive in nature. The present amendment fixing the limitation period for passing the penalty order is of a procedural nature. It gives a time in which the order is to be passed. If not passed (within that time), it cannot be passed later. This time can be varied from time to time and, if varied, the varied time will apply and not the previous time. Any amendment of the Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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