https://www.taxtmi.com/caselaws?id=7584 Transitional income-tax penalty provisions were analysed on the basis that assessment completion date can form a valid classification for applying the 1961 Act to defaults linked to the repealed 1922 Act. The commentary states that section 297(2)(g) was treated as a rational saving clause, with penalty proceedings following assessment and no Article 14 breach found. It further notes that section 271(2) was upheld because registered firms may be taxed concessively while penalty can be computed on the footing of an unregistered firm, without hostile discrimination. The discussion also states that section 271 could apply to defaults under section 22(2) of the 1922 Act through the transitional provision. en-us Tue, 25 Feb 1969 00:00:00 +0530 Mon, 02 Mar 2009 17:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7584 Transitional income-tax penalty provisions were analysed on the basis that assessment completion date can form a valid classification for applying the 1961 Act to defaults linked to the repealed 1922 Act. The commentary states that section 297(2)(g) was treated as a rational saving clause, with penalty proceedings following assessment and no Article 14 breach found. It further notes that section 271(2) was upheld because registered firms may be taxed concessively while penalty can be computed on the footing of an unregistered firm, without hostile discrimination. The discussion also states that section 271 could apply to defaults under section 22(2) of the 1922 Act through the transitional provision. Case-Laws Income Tax Tue, 25 Feb 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7584