https://www.taxtmi.com/caselaws?id=38295 Penalty proceedings under section 46(1) of the Indian Income-tax Act, 1922, were held distinct from tax recovery proceedings, so the limitation applicable to recovery did not bar the penalty action. The argument that the impugned orders were in substance recovery steps was rejected, and the limitation challenge failed. The Court also held that penalty could still be imposed after 1 April 1962 because section 21 of the Excess Profits Tax Act, 1940, incorporated the relevant provisions of the 1922 Act by reference, and repeal of the 1922 Act did not affect their continued operation for that purpose. en-us Tue, 04 Oct 1977 00:00:00 +0530 Mon, 05 Apr 2010 13:27:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38295 Penalty proceedings under section 46(1) of the Indian Income-tax Act, 1922, were held distinct from tax recovery proceedings, so the limitation applicable to recovery did not bar the penalty action. The argument that the impugned orders were in substance recovery steps was rejected, and the limitation challenge failed. The Court also held that penalty could still be imposed after 1 April 1962 because section 21 of the Excess Profits Tax Act, 1940, incorporated the relevant provisions of the 1922 Act by reference, and repeal of the 1922 Act did not affect their continued operation for that purpose. Case-Laws Income Tax Tue, 04 Oct 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38295