Penalty for concealment after 1 April 1962 is governed by the Income-tax Act, 1961 and its minimum penalty rules.

Section 297 of the Income-tax Act, 1961 distinguishes between assessments completed before 1 April 1962 and those completed on or after that date. Where reassessment is completed after 1 April 1962, penalty proceedings for concealment are to be initiated and penalty imposed under the 1961 Act, not the repealed 1922 Act. In that setting, the minimum penalty prescribed by the 1961 Act applies, as the post-1962 assessment brings the matter within the new statute's penalty regime.

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Issues: Whether penalty for concealment relating to assessment years 1954-55 to 1961-62, where reassessment was completed after 1 April 1962, was governed by the Income-tax Act, 1961 or the repealed Act of 1922, and whether the minimum penalty prescribed by the 1961 Act applied.

Analysis: The saving provisions in section 297 distinguished between cases in which the relevant assessment was completed before 1 April 1962 and those in which it was completed on or after that date. For assessments completed after 1 April 1962, penalty proceedings were to be initiated and penalty imposed under the 1961 Act. The word

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