1978 (8) TMI 5

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....s 1965-66 to 1973-74 on July 8, 1974. The net wealth returns were accepted by an assessment order dated July 27, 1974. The WTO, Kanpur, after accepting the returns, assessed the wealth-tax. The tax demanded was paid in due course. The WTO under s. 18(1)(a) of the W.T. Act can impose penalties for the delayed filing of returns. After hearing the assessee, he imposed penalties for various years a....

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....evious Commissioner and then as a result of some understanding between him and the earlier Commissioner he did not file returns for these years. The Commissioner held that there was nothing on record to substantiate this contention and the assessee's failure to file return prior to 1965-66 smacked of lack of an element of good faith in making the disclosure. It also amounted to making only a parti....

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....is returns for the earlier years and thus wanted to mitigate, the shortcomings. Learned counsel stated that the petitioner is prepared to file his returns for the earlier years and pay the tax due within a week. Since the only feature which affected the case of the petitioner was the lack of good faith in not filing his returns for the earlier years and since we do not know as to what happened pre....

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.... The learned counsel has stated that the assessee-petitioner is prepared to file his returns for those years, i.e., 1957-58 to 1964-65. There is another aspect of the matter. We find that though the Commissioner found that the assessee had not filed the returns for the earlier years, he did not invite the assessee to do so. Considering the above facts, we are of the opinion, that it would be....