TMI Blog1975 (3) TMI 5X X X X Extracts X X X X X X X X Extracts X X X X ..... -63 and assessment for the year 1961-62 was completed on 28th March, 1962, and assessment for the year 1962-63 was completed on 28th November, 1963. Thereafter, the assessments were reopened under s. 148 read with s. 147(a) on the ground that a part of the assessee's income had escaped assessment. In response to the notices under s. 148 returns were filed on February 27, 1969, for both the years w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Tribunal was legally correct in holding that the amended provisions of s. 271(1)(c)(iii) were not applicable and that the penalties have to be levied with reference to the provisions which were in force on April 1, 1961, and April 1, 1962, notwithstanding the fact that the returns of income were filed after April 1, 1968." In CIT v. Ram Achal Ram Sewak [ 1977] 106 1TR 144 (All), this court ha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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