https://www.taxtmi.com/caselaws?id=7355 Penalty proceedings under section 271 of the Income-tax Act, 1961 must be initiated while the assessment or reassessment proceedings are still pending, and a notice direction recorded in the assessment order was sufficient to show timely commencement. However, for assessment year 1961-62, the return had been filed before the 1961 Act came into force and the assessment proceeded under the 1922 Act, so the statutory basis for penalty under section 271 was not satisfied and the penalty order could not stand for that year. The authorities also had sufficient material, including earlier findings on the true nature of the business, to support concealment and inaccurate particulars. en-us Fri, 30 Aug 1968 00:00:00 +0530 Wed, 18 Feb 2009 09:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7355 Penalty proceedings under section 271 of the Income-tax Act, 1961 must be initiated while the assessment or reassessment proceedings are still pending, and a notice direction recorded in the assessment order was sufficient to show timely commencement. However, for assessment year 1961-62, the return had been filed before the 1961 Act came into force and the assessment proceeded under the 1922 Act, so the statutory basis for penalty under section 271 was not satisfied and the penalty order could not stand for that year. The authorities also had sufficient material, including earlier findings on the true nature of the business, to support concealment and inaccurate particulars. Case-Laws Income Tax Fri, 30 Aug 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7355