1987 (7) TMI 63

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....ANJANEYULU J.-This is a reference at the instance of the assessee under section 256(1) of the Income-tax Act, 1961 (the " Act." for short). The Income-tax Appellate Tribunal referred the following question for consideration of this court in connection with the income-tax assessment year 1976-77 : " Whether, on the facts and in the circumstances of the case, the Tribunal was justified in upholdi....

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....sessee is that at the relevant time when the penalty was levied on March 20, 1979, there was no provision like section 273(b) of the Act. It is pointed out that there were certain amendments which became effective from June 1, 1978. Pursuant to those amendments, section 212(3) of the Act which was in existence till June 1, 1978, had been renumbered as section 209A(1). Similarly, section 273(b) of ....

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....That apart, we find that the assessment year involved is 1976-77. The law that is applicable for the assessment year 1976-77 is the one that was in force at the beginning of the assessment year, viz., on April 1, 1976. In such circumstances, the Income-tax Officer was justified in applying the provisions of law as were in force for the assessment year 1976-77 without taking note of the amendments ....