https://www.taxtmi.com/caselaws?id=6788 Transitional penalty provisions under the Income-tax Act, 1961 are discussed as requiring a rational nexus with the legislative object: a classification based only on the chance date of completion of assessment was treated as having no connection with the default and was held incompatible with Article 14. The text also explains that penalty proceedings under section 271 could not be sustained where the assessment had arisen under the repealed Income-tax Act, 1922 and had to proceed under the old regime, because the statutory precondition for invoking the new penalty machinery was absent. The impugned penalty orders were therefore unsustainable on both constitutional and statutory grounds. en-us Wed, 07 Sep 1966 00:00:00 +0530 Mon, 02 Feb 2009 10:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6788 Transitional penalty provisions under the Income-tax Act, 1961 are discussed as requiring a rational nexus with the legislative object: a classification based only on the chance date of completion of assessment was treated as having no connection with the default and was held incompatible with Article 14. The text also explains that penalty proceedings under section 271 could not be sustained where the assessment had arisen under the repealed Income-tax Act, 1922 and had to proceed under the old regime, because the statutory precondition for invoking the new penalty machinery was absent. The impugned penalty orders were therefore unsustainable on both constitutional and statutory grounds. Case-Laws Income Tax Wed, 07 Sep 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6788