{"id":179954,"date":"1985-04-23T00:00:00","date_gmt":"1985-04-22T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-savita-m-thakar-on-23-april-1985"},"modified":"2015-12-25T16:48:34","modified_gmt":"2015-12-25T11:18:34","slug":"commissioner-of-income-tax-vs-savita-m-thakar-on-23-april-1985","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-savita-m-thakar-on-23-april-1985","title":{"rendered":"Commissioner Of Income-Tax vs Savita M. Thakar. on 23 April, 1985"},"content":{"rendered":"
Patna High Court<\/div>\n
Commissioner Of Income-Tax vs Savita M. Thakar. on 23 April, 1985<\/div>\n
Equivalent citations: (1986) 50 CTR Pat 69, 1986 158 ITR 729 Patna<\/div>\n<\/p>\n
<\/pre>\n
JUDGMENT<\/p>\n
NAZIR  AHMAD J.  – A  statement of  the case under section 256(1)  of  the Income-tax Act, 1961 (hereinafter referred to  as  “the  Act”),  has been submitted by the Income-tax Appellate  Tribunal,  “B” Bench,  Patna,  referring  the following question of law for the opinion of this court :<\/p>\n
“Whether,  on  the  facts  and in the circumstances of the case,  the  Tribunal were justified in law in holding that the  amended  time-limit of penalty under section 275 were not  applicable  to penalty proceedings which were pending on April 1, 1971 ?”\n<\/p>\n
The  facts may  be briefly  stated. The Income-tax Officer initiated  penalty  proceedings under section 271(1)(a) of the  Act for the assessment ears 1966-67, 1967-68, 1968-69 and  1969-70 as  the assessee failed  to file returns in accordance  with the provisions of section 139 of the Act. The  due  date  for  these assessment years for filing the return was 30th September for each of the assessment years in  question.  The assessments were made by the Income-tax Officer  on July  13, 1970.  The Income-tax Officer issued show-cause  notices  to  the assessee  in  each  of  the aforesaid  four years and the  assessee filed a  written explanation.  The Income-tax Officer did  not accept the explanation  and  held  that the  assessee  without  any reasonable cause failed to furnish returns within the time and  in  the manner required by section 139(1) of the Act. The Income-tax Officer found that the returns in all these years  were filed on June 23, 1970. He, therefore, imposed various amounts of  penalty against  the assessee  under section  271(1)(a) of  the Act for  all these years. The penalty  orders of the Income-tax  Officer under section 271(1)(a)  of the  Act have  been annexed and  marked as annexures A-l, A-3, A-5 and A-7, respectively.\n<\/p>\n
The assessee as per the provision of section 212(3) of the Act  was  required to file an estimate of the total income and to  pay  advance tax  accordingly. But  the assessee failed  to do so. The assessee was given an opportunity of being heard in this respect, vide notice under section 274 read with section 273 of the Act. But the assessee did not give  any  explanation. The Income-tax Officer, therefore, imposed  penalties under section 273(b) for the assessment years  1966-67, 1967-68, 1968-69, 1969-70 and 1970-71. The penalty orders of the Income-tax Officer relating to these penalties  have  been  annexed  and marked as annexures A, A-2, A-4, A-6 and A-8, respectively.\n<\/p>\n
The  assessee  appealed  before  the  Appellate  Assistant Commissioner of Income-tax who disposed of all the appeals relating  to  penalties under section 271(1)(a) of the Act by  his consolidated order dated January 11, 1974. Shri D. Sengupta,  on  behalf of the assessee, raised the point of limitation  with  regard  to  the  date  of  imposition of penalty.  The Appellate Assistant Commissioner has pointed out that the penalties in these case were imposed on March 23,  1973,  and the relevant assessments were completed on July 13, 1970. He held that in terms of section 275 of the Act,  the  penalty  proceedings should have been completed within  two years  from July  13, 1970,  i.e., by July 12, 1972.  He,  therefore,  took  the view that penalties were imposed  after  about  eight months from the expiry of the date  of limitation.  He has  also pointed out  that the appellant,  Smt. Savita M. Thakar, is legal representative of  Shri  Late  Manikant  Thakkar. He has also pointed out that  amendment regarding the limitation period by Act No. 42 of 1970 was effective from April 1, 1971, and according to  the amendment, the limitation period should count from the  end of the financial year in which the assessment was made.  The  Appellate Assistant Commissioner took the view that  as  the  amendment was effective from April 1, 1971, the  penalty orders were liable to be cancelled as penalty orders were barred by limitation. He accordingly cancelled the  penalty  orders. The order of the Appellate Assistant Commissioner  relating  to penalty under section 271(1)(a) of  the Act  has been  annexed and  marked as annexure “B” forming part of the statement of the case. It appears that although the Appellate  Assistant Commissioner  passed a consolidated order and  he also  passed separate  orders relating to the  assessment years  1967-68, 1968-69  and 1969-70, allowing the appeals for the reasons discussed in the consolidated order.\n<\/p>\n
The Appellate Assistant Commissioner passed a consolidated order  dated January 11, 1974, relating to penalties under section 273(b) of the Act relating to the assessment years 1966-67,  1967-68, 1968-69, 1969-70 and  1970-71. He has pointed  out that all these appeals are against the orders of  penalty under  section 273(b)  of the  Act and so they were  being  disposed  of  by a consolidated order. He has also pointed out that these penalties were also imposed on March  23,  1973,  by the  Income-tax  Officer  and  the assessments  were completed on July 13, 1970. He held that in  terms  of  Section  275 of  the  Act,  the  penalty proceedings  should  have  been completed within two years from  July  13, 1970, i.e., by July 12, 1972. He held that the  penalties  have been imposed after about eight months from  the  expiry  of  the  date  of  limitation.  As  the penalties were imposed on March 23, 1973, he held that the penalty  orders  under  section 273(b)  were  barred  by limitation.  He  cancelled  the penalty  orders  of  the Income-tax Officer and allowed all the appeals.\n<\/p>\n
On  the basis of the  consolidated order, the  Appellate Assistant Commissioner also passed separate orders for the assessment  years  1967-68,  1968-69, 1969-70 and 1970-71, allowing  the appeals for the  reasons discussed in  his consolidated  order  relating  to  penalty  under  section 273(b)  of  the  Act. This  consolidated  order  of  the Appellate  Assistant  Commissioner  has  been  annexed and marked  as  annexure  B-l forming part of the statement of case.\n<\/p>\n
The  Department  being  aggrieved  by  the  orders  of the Appellate  Assistant  Commissioner  filed  appeals against cancellation  of the penalty orders  relating to section 271(1)(a) as  well  as section  273(b) of  the Act.  The Tribunal  also took  the same view  as was taken by  the Appellate Assistant Commissioner  and the  Tribunal held that  the  penalties  should  have been imposed within two years  from  July  13, 1970, and as the penalties were not imposed  within  two  years from July 13, 1970, i.e., July 12, 1972, the penalty orders were barred by limitation and so  cancellation  of  the  penalty orders by the Appellate Assistant  Commissioner  were upheld  and  all  the Departmental  appeals  were dismissed. A copy of the order of  the  Tribunal  has been annexed and marked as annexure “C” forming part of the statement of the case.\n<\/p>\n
In  this  case,  none has  appeared  for  the  opposite party-assessee  and  so Mr. B. P. Rajgarhia has been heard ex  parte on behalf of  the petitioner, Commissioner  of Income-tax,  Bihar,  Patna. The facts are not disputed The due dates for returns in the various assessment years were 30th  September of each year and the assessments were made for  all  the  years on July 13, 1970. The proceedings for penalties  were  initiated  during the  course  of  the assessment  proceedings,  i.e.,  on  July  13,  1970.  The Income-tax  Officer  imposed  the penalties under sections 271(1)(a)  and  273(b) of the At in all the cases on March 23,  1973.  It cannot be doubted that under section 275 of the Act,  before  it was  amended by  the Taxation  Laws (Amendment)  Act, 1970, with effect from April 1, 1971, no order imposing  a  penalty under  this Chapter  could be passed  after the expiration of two years from the date of the  completion  of the proceedings in the course of which the  proceedings for  the imposition  of penalty have been commenced. By the Taxation Laws (Amendment) Act, 1970, the penalty  could be imposed within two years from the end of the financial year in which the proceedings, in the course of  which  action  for imposing  of  penalty  has  been initiated,  are  completed.  In the  present  case,  the assessments were completed on July 13, 1970, and so, under the unamended section 275, the penalty could be imposed on or  before July  12, 1772. But,  in view of the  amended provision, the penalty could be imposed by March 31, 1973. The  penalties have been imposed on March 23, 1973. So, if the amended section 275 is applied, then it will be within limitation.  It also cannot be doubted that the limitation had not expired when the amended provision came into force from April 1, 1971.\n<\/p>\n
It  has  been held in the case of Hajee K. Assainar v. CIT [1971]  81  ITR  423 (Ker), that if  the  amendment of a statute  deals merely  with matters  of procedure and does not  affect the rights of parties, the new procedure will, prima facie,  apply  to all  pending as  well as  future actions.\n<\/p>\n
It  has  been  held  in  the  case  of  Addl.CIT  v. Watan Mechanical  and Turning Works [1977] 107 ITR 743, which is a  Full  Bench  decision of the Andhra Pradesh High Court, that  no  one  has  a  vested and substantive right in the procedure and limitation has to be considered as a part of the  procedural law  as distinct  from substantive law. It has also been held in this decision that the liability for tax or penalty would always remain on the assessee; but if the  time  prescribed under the Act expires, the liability cannot  be  imposed  by  the authorities, the reason being that  the assessee should not  be subjected to  unending hardship.  It has  also been held  in this decision that before  the  limitation prescribed expires, if the same is enlarged,  the  limitation  being  a  procedural  one, the extended  period  of  limitation will  apply  to  such proceedings.  In the  case before  the Andhra Pradesh High Court,  under  the  old section 275 as it stood before the Amendment  Act,  1970,  the limitation for levying penalty was  due to expire by February 25, 1972. As section 275 of the Act  was  amended with  effect from  April 1,  1971, enlarging  the period  of limitation,  the High Court held that  the amended section governs the case under which the impugned  orders  levying penalty would be in time as they were  made  before  March  21, 1972. Similar view has been taken  in  the  case of CIT v. Bhikari Charan Panda [1976] 104  ITR 73  (Orissa), in the  case of CIT v.  Soubhagya Manjari,  Devi  [1976] 105 ITR 82 (Orissa), in the case of Kerala  Oil, Mills v. CIT [1980] 121 ITR 254 (Ker), in the case  of  Saraf  Trading Corporation v. CIT [1980] 123 ITR 159 (Ker)  and in the  case of  Addl. CIT  v. Raichand Amichand [1983] 144 ITR 754 (MP).\n<\/p>\n
Thus, in view of the various decisions mentioned above, it has  to be  held that  as in this case, the limitation was still running on April 1, 1971, the amended section 275 of the  Act  will  be applicable as it enlarged the period of limitation  and so the penalties imposed by the Income-tax Officer on March 23, 1973, were not barred by limitation.\n<\/p>\n
In  view  of  my above discussion, I hold that the penalty orders  of  the  Income-tax  Officer  were  not  barred by limitation and so the Tribunal was not justified in law in holding  that  the  amended  time-limit  of  penalty under section  275 of  the Act  was not applicable  to penalty proceedings which  were  pending on  April 1,  1971. The question  is answered  in the negative  and in favour of Revenue  and  against the assessee. There will be no order as to costs.\n<\/p>\n
UDAY SINHA J. – I agree.<\/p>\n","protected":false},"excerpt":{"rendered":"
Patna High Court Commissioner Of Income-Tax vs Savita M. Thakar. on 23 April, 1985 Equivalent citations: (1986) 50 CTR Pat 69, 1986 158 ITR 729 Patna JUDGMENT NAZIR AHMAD J. – A statement of the case under section 256(1) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”), has been submitted by the […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[8,26],"tags":[],"class_list":["post-179954","post","type-post","status-publish","format-standard","hentry","category-high-court","category-patna-high-court"],"yoast_head":"\nCommissioner Of Income-Tax vs Savita M. 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