COMMISSIONER OF WEALTH TAX Vs. RAMNIKLAL D MEHTA

JUDGEMENT

(1.) IN terms of a direction given by this court under Section 27(3) of the W.T. Act at the instance of the revenue, the Cuttack Bench of the Wealth-tax Appellate Tribunal has stated these cases and has referred the following common question for the opinion of the court:

(2.) WE are concerned with assessment years 1965-66 to 1971-72. For all these years, the assessee filed his return on November 2, 1972, although he had been served with notices under Section 17 of the Act for the three latter assessment years out of these, namely, 1969-70 to 1971-72. Proceedings for the imposition of penalty were initiated for the non-filing of returns and as the assessing officer was not satisfied about the existence of any reasonable cause on the basis of the explanation offered, he imposed various amounts of penalties for these years.