O.CHINNAPPA REDDY, J.

1. On March 17, 1970, the assessee made a voluntary disclosure of income of Rs. 1,30,000 which was allowed to be spread over equally over the four assessment years 1961-62, 1962-63, 1963-64 and 1964-65. For the assessment year 1961-62, the assessee had not filed a return of income on the ground that she had no taxable income. She had not filed any estimate of advance tax to be paid by her under section 18A(3). After the settlement pursuant to the voluntary disclosure, she filed a return on March 25, 1970, for the assessment year 1961-62, showing an income of Rs.450 from house property and an income of Rs.32,500 disclosed by her under the settlement. The Income-tax Officer levied a penalty of Rs. 3,608 under section 271(1)(a). For the assessment year 1964-65, the assessee had filed an estimate of advance tax showing an income of Rs. 36,800 and the tax payable by her as Rs. 10,700. Thereafter she filed return showing her income as Rs. 35,615. After the settlement pursuant to the voluntary disclosure, the Income-tax Officer completed the assessment for the assessment year 1964-65 on a total income of Rs. 1,70,298. Penalty of Rs. 7,660 was levied on her un