https://www.taxtmi.com/caselaws?id=6790 Transitional penalty provisions under the Income-tax Act, 1961 are discussed in relation to concealment proceedings for an earlier assessment year completed after 1 April 1962. The text states that such proceedings could be initiated under the new Act, and that the reference to notice under the repealed law did not carry the entire penalty regime with it. It also explains that Article 20(1) was not attracted because no prosecution had been launched, the feared prosecution was speculative, and income-tax penalty was treated as a civil remedial consequence for tax evasion rather than punishment for an offence. The note further records that the presence of a minimum penalty under the new Act did not make the regime constitutionally harsher. en-us Fri, 12 Mar 1965 00:00:00 +0530 Mon, 02 Feb 2009 10:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6790 Transitional penalty provisions under the Income-tax Act, 1961 are discussed in relation to concealment proceedings for an earlier assessment year completed after 1 April 1962. The text states that such proceedings could be initiated under the new Act, and that the reference to notice under the repealed law did not carry the entire penalty regime with it. It also explains that Article 20(1) was not attracted because no prosecution had been launched, the feared prosecution was speculative, and income-tax penalty was treated as a civil remedial consequence for tax evasion rather than punishment for an offence. The note further records that the presence of a minimum penalty under the new Act did not make the regime constitutionally harsher. Case-Laws Income Tax Fri, 12 Mar 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6790