SAMBASIVA RAO, ALLADI KUPPUSWAMI, J.

( 1 ) IS there an occasion to introduce the doctrine of mens rea into section 271 (1) (a) read with sub-clause (i) of that section of the indian Income-tax Act, 1961 Seeking an answer to this question, these four writ appeals have been directed by Chinnappa reddy and Jeevan Reddy, JJ. ,to be placed before Full Bench.

( 2 ) IT is not necessary for answering the question and also forthe adjudication of the four appeals before us to go into the facts in minute detail. Broadlystated, the material facts are The respondents are assessees which are firms. They failed to file their returns for the years 1965-66 to l969-70 within the time prescribed under the Indian Income-tax Act, 1961 (hereinafter referred to as the Act ). An explanation was tendered for this delay saying that the person who was in charge of the accounts of the firms was unable to look after the affairs of the firms for sometime owing to some personal reasons. The income-tax Officer was not inclined to accept this explanation and levied penalties for late submission of the returns. The respondents preferred revision petitions before the Commissioner of Incometax. Before him, the reason