(1.) MOVED by the Revenue, this court under Section 27(3) of the W.T. Act, 1957 (hereinafter referred to as "the Act"), directed the Wealth-tax Appellate Tribunal, Cuttack Branch, to state a case and refer the following common question in respect of assessment years 1964-65 to 1970-71.
(2.) 30th September of the respective year was the due date for submission of the returns. The returns were, however, filed for the first year in August, 1972 (sic) and for the other years on different dates in 1970 (sic). The WTO initiated proceedings, called upon the assessee to show cause and ultimately imposed varying penalties for the years under Section 18(1)(a) of the Act. The AAC did not accept the assessee's explanation and confirmed the imposition. In second appeal the Tribunal held: