COMMISSIONER OF WEALTH TAX Vs. SITARAM SINGHANIA

JUDGEMENT

(1.) THE Patna Bench "B" of the Income-tax Appellate Tribunal has sought the opinion of this court under Section 27(1) of the W.T. Act (Act 27 of 1957), on the under-mentioned question, which is common to all the assessment years in question. THE question referred for opinion of this court is :

(2.) THE facts giving rise to the aforesaid question are as under :

(3.) IF, however, the question is to be understood in the light as had been argued before the Tribunal that the assessee was debarred from applying for the extension of date for filing the returns of wealth after the expiry of the statutory date, we think, here again, the question will assume a mere academic importance, because if the assessee had a reasonable cause for default in filing the returns 6f wealth for a certain period, whether the law permitted him to file an application for extension of time or not, will be irrelevant. But even if it be assumed for the sake of argument that the application had been filed for extension of time beyond the statutory period, we do not think there is any law which debars an assessee from praying for extension of time for filing return of wealth after such statutory date.