NARENDRA SHARMA Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) The petitioner, Narendra Sharma, was assessed to income-tax for the assessment year 1961-62 by the Income-tax Officer, Central Circle XV, Calcutta. Although the order of assessment was passed on the 24th March, 1966, it was made under the provisions of Section 23(3) of the Indian Income-tax Act, 1922 (hereinafter referred to as "the repealed Act"). It is not disputed that all the notices issued to the petitioner by the appropriate Income-tax Officer in connection with the aforesaid assesement proceedings, were also issued under the provisions of the repealed Act.

(2.) On the 23rd March, 1966, the said Income-tax Officer issued two notices on the petitioner proposing to initiate proceedings for imposition of penalty under the provisions of Section 274 read with Section 271 of the Income-tax Act, 1961 (hereinafter referred to as "the Act").

(3.) The said two notices are set out hereinbelow :