https://www.taxtmi.com/caselaws?id=7662 Section 297(2)(g) of the Income-tax Act, 1961 was analysed as a transitional provision making the new penalty regime applicable to earlier assessment years completed after 1 April 1962. The majority treated penalty proceedings under the taxing statute as civil sanctions, so Article 20(1) did not bar their application, and upheld the date-based classification under Article 14 as having a rational nexus with the statutory object. On the second issue, the majority held that section 271 could operate through the saving clause for such pending matters, while the dissent considered the classification artificial and the new penalty regime inapplicable to proceedings arising under the repealed Act. en-us Mon, 03 Nov 1969 00:00:00 +0530 Tue, 17 Mar 2009 10:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7662 Section 297(2)(g) of the Income-tax Act, 1961 was analysed as a transitional provision making the new penalty regime applicable to earlier assessment years completed after 1 April 1962. The majority treated penalty proceedings under the taxing statute as civil sanctions, so Article 20(1) did not bar their application, and upheld the date-based classification under Article 14 as having a rational nexus with the statutory object. On the second issue, the majority held that section 271 could operate through the saving clause for such pending matters, while the dissent considered the classification artificial and the new penalty regime inapplicable to proceedings arising under the repealed Act. Case-Laws Income Tax Mon, 03 Nov 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7662