1987 (5) TMI 31

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....o the assessment years 1966-67 and 1967-68, the Income-tax Appellate Tribunal, " A " Bench, Patna, has referred the following question of law to this court: " Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that penalties under section 271(1)(c) were to be levied for the assessment years 1966-67 and 1967-68 at the rates effective prior to April 1,....

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....itiated penalty proceedings and on completion thereof for the assessment year 1966-67, penalty was imposed at Rs. 13,060 and for the assessment year 1967-68, penalty was imposed at Rs. 19,343 in accordance with the law relating to the rate of penalty in force from April 1, 1968. The assessee, being aggrieved by the imposition of penalty, preferred two appeals before the Appellate Assistant Commiss....

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....ani Punj v. CIT [1986] 157 ITR 330. In the Full Bench case, their Lordships were dealing with the case under section 18 of the Wealth-tax Act which is in pari materia with section 271 of the Act and it has been laid down that the rate of penalty would be imposable in accordance with the law which was in force on the date of satisfaction of the Wealth-tax Officer, i.e., the date when the proceeding....