https://www.taxtmi.com/caselaws?id=7464 A transitional tax classification based on whether assessment was completed before or after 1 April 1962 was analysed as constitutionally valid because the date of completion was an intelligible differentia with a rational nexus to curbing tax evasion. Penalty proceedings were treated as distinct from assessment, and the statutory scheme applied the 1961 Act where assessment was completed after that date. The note further states that penalty under section 271(1)(c) could be imposed even though the return had been filed and assessment began under the 1922 Act, because the relevant proceedings were treated as proceedings under the successor Act for that purpose. en-us Fri, 24 Jan 1969 00:00:00 +0530 Fri, 20 Feb 2009 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7464 A transitional tax classification based on whether assessment was completed before or after 1 April 1962 was analysed as constitutionally valid because the date of completion was an intelligible differentia with a rational nexus to curbing tax evasion. Penalty proceedings were treated as distinct from assessment, and the statutory scheme applied the 1961 Act where assessment was completed after that date. The note further states that penalty under section 271(1)(c) could be imposed even though the return had been filed and assessment began under the 1922 Act, because the relevant proceedings were treated as proceedings under the successor Act for that purpose. Case-Laws Income Tax Fri, 24 Jan 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7464