1966 (9) TMI 22

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....it applicants who filed a petition before this court to set aside an order, exhibit P-8, imposing penalty for non-payment of certain amounts covered by two earlier penalty orders, exhibits P-1 and P-2. Exhibits P-1 and P-2 were passed against the appellants for alleged concealment of income and for non-payment of advance tax under section 18A of the Indian Income-tax Act, 1922. The question is ....

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....come-tax Officer, C-Ward, Allahabad. The basis of the decision of the Allahabad High Court, as we read the judgment in that case, is the interpretation placed by that court on the decisions of the Supreme Court in C. A. Abraham v. Income-tax Officer, Kottayam, and in Commissioner of Income-tax v. Bhikaji Dadabhai & Co. With great respect we do not think that the interpretation placed by the Allaha....