https://www.taxtmi.com/caselaws?id=7133 Where a return for an assessment year was filed before the Income-tax Act, 1961 commenced, the saved assessment proceedings continued under the repealed Act, and the concealment satisfaction was reached in those proceedings. On that footing, the statutory precondition for initiating penalty under section 271(1) was not satisfied in proceedings under the new Act. Sections 297(2)(f) and 297(2)(g) were treated as saving and allocating the applicable penalty regime, not as creating a fresh liability or displacing the conditions attached to section 271(1). Penalty under section 271(1)(c) read with section 274(2) was therefore not sustainable. en-us Thu, 20 Jul 1967 00:00:00 +0530 Wed, 11 Feb 2009 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7133 Where a return for an assessment year was filed before the Income-tax Act, 1961 commenced, the saved assessment proceedings continued under the repealed Act, and the concealment satisfaction was reached in those proceedings. On that footing, the statutory precondition for initiating penalty under section 271(1) was not satisfied in proceedings under the new Act. Sections 297(2)(f) and 297(2)(g) were treated as saving and allocating the applicable penalty regime, not as creating a fresh liability or displacing the conditions attached to section 271(1). Penalty under section 271(1)(c) read with section 274(2) was therefore not sustainable. Case-Laws Income Tax Thu, 20 Jul 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7133