(1.) BOTH the cases have been heard together and are being disposed of by this common judgment.
(2.) THESE references have been made under Section 27 of the Wealth-tax Act, 1957, at the instance of the Commissioner of the Income-tax for the opinion of this court on the following common question :
(3.) MR. B. P. Rajgarhia, appearing for the Revenue, has rightly urged before us that the Tribunal was justified in imposing the penalty for 13 months only and not for 15 months as held by the Wealth-tax Officer and the Appellate Assistant Commissioner. Under such circumstances, we hold that the penalty will be leviable only for 13 months.