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.... case of M/s Jain Bros.& Others Vs. The Union of India and Other (77 I.T.R. 107) was reported. In this case, the supreme Court have observed as under:- " For the imposition of a penalty in respect of an assessment for the year ending on March, 31, 1962 or any earlier year which is completed after 1st day of April, 1962, the proceedings have to be initiated and the penalty imposed in accordance ....