COMMISSIONER OF WEALTH TAX ADDL Vs. MANJULADEVI MUCHHAL

JUDGEMENT

(1.) THIS is a reference made by the Income-tax Appellate Tribunal under Section 27(1) of the W.T. Act, 1957.

(2.) THE relevant assessment years are 1961-62, 1962-63 and 1963-64. It is stated that the returns for these years fell due on 30th June, of the respective years 1961, 1962 and 1963. THE returns were ultimately filed on 18th November, 1969. THE proceedings for these three years were disposed of by a common judgment by the Tribunal and at the instance of the CWT, this reference has been made for answering the following questions :

(3.) IN CWT v. Ram Narain Agrawal [1977] 106 ITR 965, 968 a Division Bench of the Allahabad High Court considered this question and held ;