COMMISSIONER OF WEALTH-TAX Vs. S L KHUNNAH

JUDGEMENT

(1.) In this reference, the questions referred to this court for opinion by the Income-tax Appellate Tribunal are :

(2.) These very questions have been referred to in the other connected references.

(3.) The assessee, S.L. Khunnah, is an individual. He was a partner in L.N. Khunnah and Sons. The dispute relates to penalties levied on him under Section 18(1)(a) for the assessment years 1970-71 and 1971-72. The returns for these two years had been filed on December 30, 1971. Since in the opinion of the Wealth-tax Officer, there was delay in the filing of the returns, he issued notices for levy of penalty under Section 18(1)(a) of the Wealth-tax Act.