Clear statutory text prevails over legislative assurances in penalty for delayed income-tax return filing.

Clear and unambiguous statutory language governed the filing of returns and penalty for default under the Indian Income-tax Act, 1922. A person with assessable income had to file the return within the period fixed by public notice under section 22(1), and failure attracted penalty under section 28; individual notice under section 22(2) was not mandatory in every case. Where the assessee had sought and obtained extension but still filed the return much later, the continuing default remained liable to penalty, and statements made during the legislative process could not override the enacted text or excuse the delay.

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Issues: Whether assurances given on the floor of the House at the time of enactment of section 28 of the Indian Income-tax Act, 1922 could be relied upon to interpret the provision and defeat penalty for the assessee's default in filing the return within the extended time.

Analysis: The statutory language governing the filing of returns and the imposition of penalty was held to be clear and unambiguous. A person with assessable income was required to file the return within the period prescribed by the public notice under section 22(1) of the Indian Income-tax Act, 1922, and failure to do so attracted liability under section 28. Individual notice under section 22(2) was not mandatory in every case. The assessee had been served with notice under section 34, had sought time, was granted extension, and still filed the return only much later. In that setting, extraneous statements made during the legislative process could not control the meaning of the enacted text or excuse the continuing default after the extended date.

Conclusion: The assurances on the floor of the House were rightly ignored, and the question was answered in the affirmative in favour of the Revenue.

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