Wealth-tax penalty rate follows the law in force on the date of default, not a later enhancement.

Penalty for late filing of wealth-tax returns had to be levied at the rate in force on the respective due dates, because the default was complete when the returns became overdue. The later enhanced rate could not be applied to a default already committed, and the Tribunal rejected the Revenue's contention that the default continued after amendment so as to attract the higher rate. The penalty was therefore confined to the pre-amendment rate applicable on each date of default.

---

---

Issues: Whether penalty for late filing of wealth-tax returns was to be computed at the rate in force on the dates of default or at the enhanced rate introduced later.

Analysis: The delay in filing the returns made the default complete on the respective due dates. The governing law for levy of penalty was therefore the law in force on those dates, and the later enhancement could not be applied to a default already committed. The Tribunal followed the binding High Court decision relied upon by the appellate authority and rejected the Revenue's contention that the default continued after the amendment so as to attract the higher rate.

Conclusion: Penalty was to be calculated only at the rate existing on the dates of default, and not at the later enhanced rate.

---