Jurisdiction under section 273A cannot reach earlier penal interest levies; pending tax applications must be decided independently.

Section 273A of the Income-tax Act, 1961 could not be applied to penal interest levied for earlier assessment years because the provision came into force only from 1 October 1975. The Commissioner therefore lacked jurisdiction to entertain a revision against a levy completed before that date, and the impugned order was void and without legal force. Pending applications before the income-tax authorities had to be considered independently on their own merits and in accordance with law, without being influenced by the Commissioner's order.

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Issues: Whether the Commissioner had jurisdiction under section 273A of the Income-tax Act, 1961 to entertain a revision against penal interest levied before that provision came into force, and whether the pending applications before the income-tax authorities had to be decided independently.

Analysis: Section 273A was inserted only by the Taxation Laws (Amendment) Act, 1974 with effect from 1 October 1975, whereas the penal interest in question had been levied in respect of earlier assessment years and had been completed before that date. The Commissioner therefore could not assume jurisdiction under a provision that had no application to the earlier levy. The impugned order was consequently made without jurisdiction and had no legal force. Since the petitioner stated that applications were already pending before the income-tax authorities, those applications were required to be dealt with on their own merits and in accordance with law, uninfluenced by the Commissioner's order.

Conclusion: The challenge succeeded. The Commissioner's order was treated as void for want of jurisdiction, and the concerned income-tax authorities were directed to decide the pending applications on merits and in accordance with law.

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