(1.) IN these references, the INcome-tax Appellate Tribunal (hereinafter referred to as "the Tribunal"), has referred the following questions under Section 256(1) of the I.T. Act, 1961 (hereinafter referred to as "the Act").
(2.) WHETHER the penalty provisions under section 271(1)(a) were attracted on the failure of the assessee to file a fresh return in compliance with notice under Section 147(1)/148 of the Income-tax Act, 1961 ?"
(3.) IN order to answer the first question, it will be necessary to take note of the provisions of Section 148 of the Act which reads as under :