Penalty Under Income Tax Act Section 221(1) Deemed Invalid Due to Misalignment with Section 140A(3) Amendments.

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....Penalty imposed u/s 221(1) r.w.s. 140A(3) - non-payment of self-assessment tax - Return of Income as filed u/s 139(1) itself was declared an invalid Return - scope of Sec.140A(3) - without there being any requisite corresponding amendment to Sec. 221 of the Act in consonance with the amendments carried out in Sec. 140A(3) of the Act w.e.f. 01.04.1989, the Assessing Officer erred in levying the impugned penalty.....