(1.) THIS is a reference under s. 256(1) of the I.T. Act, 1961 (Referred to hereinafter as 'the said Act').
(2.) THE question referred to us for our determination in this reference is as follows :
(3.) SECTION 271 of the said Act deals with the failure to furnish returns, comply with notices, concealment of income, and so on. There is no dispute that under the provisions of sub -s. (1) of s. 271, the assessee became liable to the payment of penalty for the late submission of its returns. Sub -section (2) of s. 271 read thus :