G.N.RAY, S.MOHAN
Commissioner Of Income Tax (Additional) , Gujarat – Appellant
Versus
I. M. Patel And Company – Respondent
JUDGMENT
S. MOHAN, J.:- All the three appeals can be dealt with under the common judgment since the assessment years are different while the assessee -the respondent is one and the same. The three assessment years in question are 1964-65, 1965-66 and 1966-67.
2. For the year 1964-65, the assessee returned an income of Rs. 48,000/ -while he was assessed on an income of Rs. 58,557/- imposing a penalty of Rs. 9,690/ - For the year 1965-66, the assessee returned an income of Rupees 45,000/- He was assessed on an income of Rs.52,337/- together with the penalty of Rs. 6.1115. For the year 1966-67, he returned an income of Rupees 5 1,000 while he was assessed on an income of Rs. 62,560 and a penalty of Rs. 3,915 was imposed. It requires to be stated, at this stage, that for the respective assessment years the returns, as per the statute, ought to have been filed on July 31, 1964, July 31, 1965 and July 31, 1966 respectively. However, the assessee filed the returns for all these years on March 24, 1967. It was the filing of these belated returns which obliged the assessing authority to impose penalty as warranted under Section 271 (1)(a) of the Income-tax Act, 1961, (here in after referred t
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