https://www.taxtmi.com/caselaws?id=15823 Penalty under section 9 of the Companies (Profits) Surtax Act, 1964, was not attracted where the return was filed late but before assessment was completed. The statutory scheme allowed a return or revised return to be furnished up to the time of assessment under section 5(3), and section 9 applied only to failure, without reasonable cause, to furnish the return required under section 5. On a strict reading of the taxing statute, no liability could be implied beyond the words used, and any ambiguity had to be resolved in favour of the assessee. en-us Mon, 25 Jan 1999 00:00:00 +0530 Sat, 29 Aug 2009 13:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15823 Penalty under section 9 of the Companies (Profits) Surtax Act, 1964, was not attracted where the return was filed late but before assessment was completed. The statutory scheme allowed a return or revised return to be furnished up to the time of assessment under section 5(3), and section 9 applied only to failure, without reasonable cause, to furnish the return required under section 5. On a strict reading of the taxing statute, no liability could be implied beyond the words used, and any ambiguity had to be resolved in favour of the assessee. Case-Laws Income Tax Mon, 25 Jan 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15823