TMI Blog1980 (11) TMI 7X X X X Extracts X X X X X X X X Extracts X X X X ..... ese are applications under s. 27(3) of the W.T. Act. 1957, hereinafter called the Act. The material facts giving rise to these applications briefly are as follows: For the assessment years 1964-65 to 1966-67, the assessee, Guljarilal Maniram, failed to file returns in time under the provisions of the Act, and notices under s. 18(1)(a) of the Act were accordingly issued to the assessee to show ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ference to this court. The Tribunal rejected the applications. The department has, therefore, filed these applications. Shri Bagadiya, learned counsel for the department, contended that the question as to whether the Tribunal was justified in holding that penalty under s. 18(1)(a) of the Act was leviable in accordance with the provisions of s. 18(1)(a) of the Act, as they stood prior to their am ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entative of the assessee was also not raised before the AAC and was not allowed to be raised before the Tribunal. The non-applicant has not sought any reference on that question. In these circumstances, the contention urged on behalf of the Department that a question of law does arise deserves to be upheld. We, therefore, direct the Tribunal to state the case and refer the following question of la ..... X X X X Extracts X X X X X X X X Extracts X X X X
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