1976 (11) TMI 34

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Y J.--The assessee filed a return after a delay of four years and three months. The delay stood unexplained. Proceedings for levy of penalty were instituted. The income of the assessee was first assessed at Rs. 58,920 and tax of Rs. 23,265 was levied. The income was later revised to Rs. 1,44,353 and the tax determined was Rs. 91,924. There was a further revision and the income was finally assessed....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt of section 271(1)(a)(i) in which the expression now used is " assessed tax " and not " tax payable ". This amendment has been made retrospective and the amending Act further provides that it shall be deemed to have always been substituted. In view of this amendment, it is clear that the only answer that we can return to the question has to be in the negative. Shri Gupta argued that in the exerc....