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TMI Blog1986 (7) TMI 155X X X X Extracts X X X X X X X X Extracts X X X X ..... 71-72 1972-73. 2. The returns of wealth for the asst. yrs. 1971-72 and 1972-73 due to be filed June 1971 and June 1972 respectively were filed on 28th July, 1976. The WTO completed the assessment for those years on 28th March, 1976 and 25th Aug., 1976 respectively. He thereafter initiated penalty proceedings against the assessee under s. 18 (1) (a) of the WT Act and imposed penalties of Rs. 9 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e filed. 3. Now it is contended by the assessee that the said judgment of the Hon'ble Supreme Court in the case of Suresh Seth has been over-ruled by the Hon'ble Supreme Court in the case of Mayarani Punj vs. CIT (1986) 50 CTR (SC) 191 : (1986) 157 ITR 330 (SC). It has been held in the case of Mayarani Punj that the crucial date for the purpose of penalty is the date of completion of the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l Representative on the other hand opposed the application. According to him, the order of the Tribunal is based on the case law produced before it and such there is no error in the order. 5. Since the order of the Tribunal in contrary to the decision of the Hon'ble Supreme Court in the case of Mayarani Punj which was already rendered though not available at the time of hearing it is obviously ..... X X X X Extracts X X X X X X X X Extracts X X X X
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