Amended wealth-tax penalty scale applies for the relevant period where binding precedent governs the assessment years

The Court applied its earlier precedent on analogous penalty provisions under the Wealth-tax Act and declined to reopen that ruling. It held that the prior decision remained binding, with no sufficient ground to reconsider it, and applied that authority to the relevant assessment years. On that basis, the amended enhanced penalty scale governed the period in question where the law so provided, and the issue was resolved in favour of the Revenue.

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Issues: Whether penalty under section 18(1)(a) of the Wealth-tax Act, 1957, for the relevant assessment years was to be computed under the pre-amendment provision or under the amended enhanced scale applicable after the relevant amendment dates.

Analysis: The Court followed its earlier ruling on the analogous penalty provisions and declined to reopen that precedent. It held that the earlier decision governing the issue had considered the relevant principle and remained binding, and that there were no sufficient grounds to reconsider it. Applying that precedent, the amended penalty scale was held applicable where the law so provided for the period in question.

Conclusion: The issue was answered in favour of the Revenue and against the assessee, and the penalty was held to be governed by the amended provisions for the relevant period.

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