1981 (12) TMI 77
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 1973-74, the WTO noted that that there was a delay of 22 months in filing of the return by the assessee. It is seen from the penalty order that the WTO noted that the assessee could have filed the return of income u/s 139(1) of the Act on or before 15th August, 1973. He noted, however, that the return was filed on 4th July, 1975. Here it may be mentioned that the WTO possibly had in mind the prov....
X X X X Extracts X X X X
X X X X Extracts X X X X
....the return voluntarily on 4th July, 1975, when the same was filed in compliance with the notice issued by the WTO u/s 17. The case of the assessee is that she was of the genuine belief that her wealth was below the taxable limit, particularly when the ornaments meant fot her personal use should also be included in the wealth. It is stated that the wealth of the assessee during the year in question....
X X X X Extracts X X X X
X X X X Extracts X X X X
..... 1,00,364 and Rs. 1,13,700 for the asst. yr. 1971-72, 1972-73 and 1973-74. Thus it is urged that under these facts the penalty sustained by the AAC may be cancelled. The Revenue, on the other hand, submit that the assessee was assisted by the tax expert and as such there was no room for her to state that she was not aware of the liability to include the gold ornaments in her wealth. Briefly speak....