Section 234F Fee Justified for Late Income Tax Returns u/s 139(1); Financial Status Irrelevant to Classification.

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....Levy of Fee u/s 234F for default in furnishing return of income u/s 139(1) - The revenue is justified in holding that the object of the provision is thus intended to ensure proper and timely filing of return. The gravamen of the offence is failure to submit the return within a stipulated time. So far as these persons are concerned, they form a class by themselves. Whether a person is richer comparatively than the other has no relevance to this classification.....