https://www.taxtmi.com/caselaws?id=277166 A penalty under a taxing statute can be imposed only where the conduct falls squarely within the express language creating liability, and a deeming provision cannot be extended by implication to enlarge a penal charge. On that construction, failure to comply with section 18A(3) of the Indian Income-tax Act, 1922 is not covered by section 28(1), because that provision applies only where a return required by notice under section 22 or section 34 is not furnished, or is not furnished in time and manner. Penalty cannot therefore be imposed under section 28(1) for non-compliance with section 18A(3). en-us Thu, 04 Nov 1954 00:00:00 +0530 Tue, 27 Nov 2018 16:29:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277166 A penalty under a taxing statute can be imposed only where the conduct falls squarely within the express language creating liability, and a deeming provision cannot be extended by implication to enlarge a penal charge. On that construction, failure to comply with section 18A(3) of the Indian Income-tax Act, 1922 is not covered by section 28(1), because that provision applies only where a return required by notice under section 22 or section 34 is not furnished, or is not furnished in time and manner. Penalty cannot therefore be imposed under section 28(1) for non-compliance with section 18A(3). Case-Laws Income Tax Thu, 04 Nov 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277166