1970 (11) TMI 40

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..... concealment, the provision at the time the concealment took place must be applied - - - - - Dated:- 17-11-1970 - Judge(s) : M. U. ISAAC., P. GOVINDAN NAIR. JUDGMENT This relates to the question of imposition of penalty arising from the assessment that has been made for the year 1958-59 on the deceased assessee, Mukundan, in relation to which assessment we answered two questions just now in .....

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..... revenue invited our attention to the Explanation introduced by an amendment effected by the Finance Act of 1964 to section 271(1) which came into force in 1964 and he urged that the notice for the imposition of penalty having been issued after this amendment, the provision in the Explanation must apply and under that provision penalty can be imposed. We do not think that that Explanation can have .....

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