Venkataramiah, J.—The petitioner in these two writ petitions was an assessee under the Wealth-tax Act, 1957 (hereinafter referred to as "the Act"), during the assessment years 1969-70 and 1970-71. He filed the returns pertaining to those two assessment years beyond the prescribed time. The Wealth-tax Officer, being of the opinion that there was no reasonable cause for filing the returns beyond time, made an order under the provisions of section 18(1)(a) of the Act calling upon the petitioner to pay penalties as provided by law. Aggrieved by the orders passed by the Wealth-tax Officer levying the penalties, the petitioner approached the Commissioner of Wealth-tax with applications under sub-section (2A) of section 18 of the Act, requesting him to exercise his discretion and to reduce or waive the amount of penalties imposed on him. The Commissioner rejected both the applications. While doing so, he observed as follows :

"From 1969-70 onwards there was no reason why he should have delayed filing of returns when he was conscious of the provisions of law leading to wealth-tax liability. This in my opinion amounts to a conscious disregard of the law and the delay in filing the re