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1972 (10) TMI 31 - ANDHRA PRADESH HIGH COURT"Whether on a true interpretation of the order dated the 8th October, 1963, passed by departmental authorities with reference to the assessee's application, the penalties levied under section 221(1) of the Income-tax Act, 1961were valid ?" hold that the Income-tax Officer has passed the order dated October 8, 1963, only under section 220(6) of the Act and the same can be operative only till the disposal of the appeals before the Appellate Assistant Commissioner, and the Income-tax Officer, in the present case, is perfectly entitled to impose penalty under section 221(1) of the Act for non-payment of the arrears of tax - our answer to the question must be in the affirmative and in favour of the department. If there are any other grounds raised in the appeal by the assessee before the Appellate Tribunal, it is open to the Tribunal to pass appropriate orders in that regard
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