CHUNNILAL AND BROS Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS reference has been made under Section 256(1) of the I.T. Act, 1961 (hereinafter called " the Act "), to decide the following questions, viz.:

(2.) IT may be mentioned that the last question has been referred at the instance of the CIT, while all the other questions are referred at the instance of the assessee.

(3.) AFTER holding the prescribed enquiry on the basis of the above notices, the ITO, by order dated September 26, 1966, in each case, imposed the penalty of Rs. 7,284 and Rs. 3,338, respectively, for these two assessment years under Section 271(1)(a) of the Act. The AAC dismissed the assessee's appeals against the imposition of penalty for both years by his consolidated order dated January 4, 1967.