TaxTMI 
TaxTMI 
2003 (10) TMI 37
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....---------------------------------------- Assessment Income Income Due date of Date on which Delay in Year declared assessee filing return return was filed months in (Rs.) in (Rs.) ------------------------------------------------------------------------------------- 1980-81 18,184 18,300 ....
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....considered the prayer made by the petitioner and came to the conclusion that even though the conditions set forth in section 273A of the Act stood satisfied yet, according to him, it was a fit case for reduction rather than waiver of the penalty. Accordingly, by order dated April 28, 1986, he directed that penalty imposable under section 271(1)(a) of the Act shall be reduced to 50 per cent. of that imposable in each of the three years. He further directed that interest payable under section 139(8) of the Act shall also be reduced to 50 per cent. of that charged for all the three years. It is against this order that the present petitions have been filed under article 226 of the Constitution. The relevant part of section 273A of the Act, as ....
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....the issue of such notice has expired, prior to the issue of notice to him under section 148, voluntarily and in good faith made full and true disclosure of his income and has paid the tax on the income so disclosed, and also has, in all the cases referred to in clauses (a), (b) and (c), cooperated in any enquiry relating to the assessment of his income and has either paid or made satisfactory arrangements for the payment of any tax or interest payable in consequence of an order passed under this Act in respect of the relevant assessment year. Explanation.--For the purposes of this sub-section, a person shall be deemed to have made full and true disclosure of his income or of the particulars relating thereto in any case where the excess of....