https://www.taxtmi.com/caselaws?id=38452 The High Court held that the penalty proceedings for the assessment year 1963-64 would be governed by the Explanation to section 271(1) of the Income-tax Act, 1961. The Tribunal's decision to not apply the Explanation was deemed unjustified. The court ruled that since the return was filed after the introduction of the Explanation, the offense occurred after the Explanation was in effect, citing precedents from the Allahabad High Court. The penalty imposition was upheld, and the judgment was delivered by Sabyasachi Mukharji J., with agreement from Sudhindra Mohan Guha J. No costs were awarded in this matter. en-us Wed, 01 Feb 1978 00:00:00 +0530 Tue, 06 Apr 2010 13:09:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38452 The High Court held that the penalty proceedings for the assessment year 1963-64 would be governed by the Explanation to section 271(1) of the Income-tax Act, 1961. The Tribunal's decision to not apply the Explanation was deemed unjustified. The court ruled that since the return was filed after the introduction of the Explanation, the offense occurred after the Explanation was in effect, citing precedents from the Allahabad High Court. The penalty imposition was upheld, and the judgment was delivered by Sabyasachi Mukharji J., with agreement from Sudhindra Mohan Guha J. No costs were awarded in this matter. Case-Laws Income Tax Wed, 01 Feb 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38452