https://www.taxtmi.com/caselaws?id=177660 A penal provision was construed strictly, and the court held that no enforceable liability existed on the relevant date to require the firm to furnish an estimate of tax under Section 18A(3). Although the due date fell on 15 March 1947, the firm was then unregistered and the later registered assessee, or its partners in that assessed capacity, had not yet come into existence for that purpose. As liability to pay tax arose only upon later registration and assessment, failure to file the estimate could not attract penalty under Section 28(1)(a). en-us Wed, 19 Aug 1953 00:00:00 +0530 Thu, 14 Jan 2016 14:30:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177660 A penal provision was construed strictly, and the court held that no enforceable liability existed on the relevant date to require the firm to furnish an estimate of tax under Section 18A(3). Although the due date fell on 15 March 1947, the firm was then unregistered and the later registered assessee, or its partners in that assessed capacity, had not yet come into existence for that purpose. As liability to pay tax arose only upon later registration and assessment, failure to file the estimate could not attract penalty under Section 28(1)(a). Case-Laws Income Tax Wed, 19 Aug 1953 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177660