1975 (3) TMI 5

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....d returns of income for the assessment years 1961-62 and 1962-63 and assessment for the year 1961-62 was completed on 28th March, 1962, and assessment for the year 1962-63 was completed on 28th November, 1963. Thereafter, the assessments were reopened under s. 148 read with s. 147(a) on the ground that a part of the assessee's income had escaped assessment. In response to the notices under s. 148 ....

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.... "Whether, on the facts and in the circumstances of the case, the Tribunal was legally correct in holding that the amended provisions of s. 271(1)(c)(iii) were not applicable and that the penalties have to be levied with reference to the provisions which were in force on April 1, 1961, and April 1, 1962, notwithstanding the fact that the returns of income were filed after April 1, 1968." In CIT....