COMMISSIONER OF WEALTH-TAX Vs. P N MEHTA

JUDGEMENT

(1.) We have seen the order of the Tribunal. We have also seen the application made by the Revenue under Section 27(1) and the order of the Tribunal rejecting that application. We are of the opinion that the following three questions of law, as suggested, do hereby arise out of the order of the Tribunal:

(2.) Whether, on the facts and in the circumstances of the case, the Tribunal was, in law, justified in directing to condone the period of delay for the penalty under Section 18(1)(a) for the assessment year 1973-74 from the date of the filing of the return for 1972 73 and for the penalty under Section 18(1)(a) for the assessment years 1974-75 to 1980-81 with effect from September 5, 1980, when the return for 1973-74 was filed ?

(3.) Whether, on the facts and in the circumstances of the case, the Tribunal was, in law, justified in cancelling the penalty for the assessment year 1972-73 and reducing the penalties for the assessment years 1973-74 to 1980-81, when there was no reasonable cause with the assessee ?