https://www.taxtmi.com/caselaws?id=28889 Penalty proceedings linked to assessments completed before 1 April 1962 were treated as governed by the Indian Income-tax Act, 1922, because the transitional rule in section 297(2) made the completion date of the assessment decisive; notices issued under section 46(1) of the 1922 Act therefore did not become proceedings under section 221 of the 1961 Act. On that footing, the proviso to section 30(1) of the 1922 Act applied, so an appeal to the Appellate Assistant Commissioner was not maintainable unless the relevant tax had been paid before filing. The reference was answered against the assessee on both issues. en-us Tue, 18 Sep 1979 00:00:00 +0530 Mon, 08 Mar 2010 13:57:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28889 Penalty proceedings linked to assessments completed before 1 April 1962 were treated as governed by the Indian Income-tax Act, 1922, because the transitional rule in section 297(2) made the completion date of the assessment decisive; notices issued under section 46(1) of the 1922 Act therefore did not become proceedings under section 221 of the 1961 Act. On that footing, the proviso to section 30(1) of the 1922 Act applied, so an appeal to the Appellate Assistant Commissioner was not maintainable unless the relevant tax had been paid before filing. The reference was answered against the assessee on both issues. Case-Laws Income Tax Tue, 18 Sep 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28889