https://www.taxtmi.com/caselaws?id=6382 For computing penalty under section 271(1)(a)(i) of the Income-tax Act, the expression "the amount of tax, if any, payable by him" was construed to mean the tax payable after deducting amounts already paid, including payment made under a provisional assessment, rather than the gross tax assessed. The Court distinguished "tax payable" from "tax assessed" and held that, because the penalty provision admitted two reasonable meanings, the interpretation favourable to the assessee had to be adopted. The assessee therefore succeeded on the penalty base, and the penalty could not be computed on the full assessed tax. en-us Mon, 29 Jan 1973 00:00:00 +0530 Thu, 15 Jan 2026 15:23:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6382 For computing penalty under section 271(1)(a)(i) of the Income-tax Act, the expression "the amount of tax, if any, payable by him" was construed to mean the tax payable after deducting amounts already paid, including payment made under a provisional assessment, rather than the gross tax assessed. The Court distinguished "tax payable" from "tax assessed" and held that, because the penalty provision admitted two reasonable meanings, the interpretation favourable to the assessee had to be adopted. The assessee therefore succeeded on the penalty base, and the penalty could not be computed on the full assessed tax. Case-Laws Income Tax Mon, 29 Jan 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6382