https://www.taxtmi.com/caselaws?id=39258 Section 271(1)(a) was construed as permitting penalty for failure to file returns required under section 139(1), section 139(2), or section 148, and the words "as the case may be" did not confine penalty only to default in response to reassessment notices. Reading sections 271(1) and 297(2)(g) together, the Gujarat HC stated that penalty provisions of the new Act apply to proceedings completed after 1 April 1962. On that basis, the Income-tax Officer could in reassessment proceedings take cognizance of the assessee's earlier default under section 22(1) of the 1922 Act and levy penalty accordingly. en-us Wed, 22 Aug 1973 00:00:00 +0530 Wed, 14 Apr 2010 11:49:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39258 Section 271(1)(a) was construed as permitting penalty for failure to file returns required under section 139(1), section 139(2), or section 148, and the words "as the case may be" did not confine penalty only to default in response to reassessment notices. Reading sections 271(1) and 297(2)(g) together, the Gujarat HC stated that penalty provisions of the new Act apply to proceedings completed after 1 April 1962. On that basis, the Income-tax Officer could in reassessment proceedings take cognizance of the assessee's earlier default under section 22(1) of the 1922 Act and levy penalty accordingly. Case-Laws Income Tax Wed, 22 Aug 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39258