Penalty computation under the substituted Wealth-tax provision was upheld for assessment year 1967-68, favouring the Revenue.

For the assessment year 1967-68, penalty under the Wealth-tax Act was to be computed under the substituted form of section 18(1)(i), first effective from 1 April 1965 and later substituted by the Finance Act, 1969. Applying the ratio of the earlier decision cited in the text, the court held that the substituted provision governed the computation of penalty for that year. The penalty computation was therefore upheld, and the question was answered in favour of the Revenue and against the assessee.

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Issues: Whether the penalty for the assessment year 1967-68 was to be computed under section 18(1)(i) of the Wealth-tax Act, 1957, as substituted with effect from 1 April 1965 and thereafter as substituted by the Finance Act, 1969.

Analysis: The reference was considered only to the extent that the dispute survived for the assessment year 1967-68. Following the earlier decision referred to in the judgment and the ratio applied therefrom, the applicable provision for computing the penalty was the substituted form of section 18(1)(i). The question was answered on that basis, and the computation of penalty was upheld accordingly.

Conclusion: The question was answered in the affirmative, in favour of the Revenue and against the assessee.

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