https://www.taxtmi.com/caselaws?id=38256 The court ruled against the assessee, holding that penalty proceedings are governed by the law prevailing on the date of default, even if the return was filed before any subsequent amendments. The penalty imposed under section 271(1)(c) was deemed unjustified as the Explanation to the section, amended after April 1, 1968, was wrongly applied to an assessment year prior to the amendment. The court clarified that penalty and assessment proceedings are distinct, emphasizing the importance of applying the legislation in force at the time of the default in penalty cases. No costs were awarded due to the absence of representation by the assessee. en-us Fri, 13 Jan 1978 00:00:00 +0530 Mon, 05 Apr 2010 12:00:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38256 The court ruled against the assessee, holding that penalty proceedings are governed by the law prevailing on the date of default, even if the return was filed before any subsequent amendments. The penalty imposed under section 271(1)(c) was deemed unjustified as the Explanation to the section, amended after April 1, 1968, was wrongly applied to an assessment year prior to the amendment. The court clarified that penalty and assessment proceedings are distinct, emphasizing the importance of applying the legislation in force at the time of the default in penalty cases. No costs were awarded due to the absence of representation by the assessee. Case-Laws Income Tax Fri, 13 Jan 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38256