https://www.taxtmi.com/caselaws?id=8994 A return filed after the time allowed under section 139(1) or section 139(2), though within the extended period under section 139(4), does not count as timely for penalty purposes under section 271(1)(a). The court read the language of section 271(1)(a) in its ordinary sense and held that the saving facility in section 139(4) only permits a valid belated return before assessment; it does not remove the earlier default or extend the original time limit. The decision in Kulu Valley Transport Co. was confined to its own facts and did not govern this penalty issue, so the question was answered in favour of the Revenue. en-us Mon, 07 Aug 1972 00:00:00 +0530 Thu, 22 Jan 2026 11:43:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8994 A return filed after the time allowed under section 139(1) or section 139(2), though within the extended period under section 139(4), does not count as timely for penalty purposes under section 271(1)(a). The court read the language of section 271(1)(a) in its ordinary sense and held that the saving facility in section 139(4) only permits a valid belated return before assessment; it does not remove the earlier default or extend the original time limit. The decision in Kulu Valley Transport Co. was confined to its own facts and did not govern this penalty issue, so the question was answered in favour of the Revenue. Case-Laws Income Tax Mon, 07 Aug 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8994