https://www.taxtmi.com/caselaws?id=39867 The amended minimum-penalty provision in section 17(1)(a) of the Gift-tax Act, 1958, was held not to apply to a return-filing default committed before the Gift-tax (Amendment) Act, 1962 came into force. The relevant infringement occurs on the due date for filing the return, and penalty proceedings are distinct from assessment, so the governing law is fixed by the date of default rather than the penalty order or assessment year. In the absence of clear retrospective language, the amendment was construed as prospective, and the unamended provision alone governed the levy. en-us Mon, 23 Sep 1974 00:00:00 +0530 Thu, 15 Jan 2026 18:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39867 The amended minimum-penalty provision in section 17(1)(a) of the Gift-tax Act, 1958, was held not to apply to a return-filing default committed before the Gift-tax (Amendment) Act, 1962 came into force. The relevant infringement occurs on the due date for filing the return, and penalty proceedings are distinct from assessment, so the governing law is fixed by the date of default rather than the penalty order or assessment year. In the absence of clear retrospective language, the amendment was construed as prospective, and the unamended provision alone governed the levy. Case-Laws Income Tax Mon, 23 Sep 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39867