Reassessment under the 1961 Income-tax Act brings penalty proceedings within the new regime, with jurisdiction upheld.

For section 297(2)(g) of the Income-tax Act, 1961, "assessment" includes reassessment within the meaning of section 2(8). Penalty proceedings arising from reassessment orders made after 1 April 1962 are therefore governed by the 1961 Act, even if they relate to earlier assessment years. On that interpretation, penalty under section 271(1)(c) could be imposed and the Inspecting Assistant Commissioner had jurisdiction to do so. The provision was read consistently with the statutory scheme and the interpretation accepted by the Supreme Court.

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Issues: Whether penalty proceedings in respect of reassessments completed after 1 April 1962, but relating to earlier assessment years, were governed by section 297(2)(g) of the Income-tax Act, 1961, and whether the Inspecting Assistant Commissioner had jurisdiction to impose penalty under section 271(1)(c).

Analysis: The expression "assessment" in section 297(2)(f) and section 297(2)(g) was read in the light of section 2(8) of the Income-tax Act, 1961, which includes reassessment. Since the penalty proceedings arose out of reassessment orders made after the commencement of the 1961 Act, the later clause applied. The provision was also understood consistently with the statutory scheme and the interpretation placed on it by the Supreme Court.

Conclusion: Penalty could be imposed under section 271(1)(c) of the Income-tax Act, 1961, and the Inspecting Assistant Commissioner had jurisdiction; the answer was in the affirmative and in favour of the Revenue.

Final Conclusion: Reassessment completed after the commencement of the 1961 Act attracted the penalty machinery under the repealed-and-savings provision, and the penalty orders were not void for want of jurisdiction.

Ratio Decidendi: For the purpose of section 297(2)(g) of the Income-tax Act, 1961, the term "assessment" includes reassessment, so penalty proceedings arising from reassessments completed after 1 April 1962 are governed by the 1961 Act.

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