https://www.taxtmi.com/caselaws?id=67301 For assessment years ending on 31 March 1962 or earlier, where assessment was completed on or after 1 April 1962, penalty proceedings had to be taken under the Income-tax Act, 1961 rather than the repealed Income-tax Act, 1922. Section 297(2)(g) made the completion date of assessment decisive for the applicable penalty regime, and penalty was treated as an independent proceeding rather than a mere ation of assessment. On that basis, penalty under section 271(1)(a) of the 1961 Act was the proper provision, but the orders could not survive because the limitation period under section 275(a)(i) had already expired. en-us Wed, 20 Dec 1978 00:00:00 +0530 Thu, 10 Mar 2011 10:03:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=67301 For assessment years ending on 31 March 1962 or earlier, where assessment was completed on or after 1 April 1962, penalty proceedings had to be taken under the Income-tax Act, 1961 rather than the repealed Income-tax Act, 1922. Section 297(2)(g) made the completion date of assessment decisive for the applicable penalty regime, and penalty was treated as an independent proceeding rather than a mere ation of assessment. On that basis, penalty under section 271(1)(a) of the 1961 Act was the proper provision, but the orders could not survive because the limitation period under section 275(a)(i) had already expired. Case-Laws Income Tax Wed, 20 Dec 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=67301