Rastogi, J. - (1.) The Income-tax Appellate Tribunal, Delhi Bench-A, has referred the following questions at the instance of the assessee, for the opinion of this court: "1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in holding that Section 18(1)(a) of the Wealth-tax Act, as amended w.e.f. April 1, 1969, would apply in imposing the penalty ?
(2.) Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in sustaining the penalty under Section 18(1)(a) more than half of the tax levied ? "2. The assessee is an individual. For the assessment year 1967-68, the assessee should have filed her return of wealth-tax by June 29, 1967, and for the assessment year 1 968-69, by 29th of June, 1968. The returns were not filed by those dates, but were filed on November 15, 1969, that is, after a delay of 29 complete months for 1967-68 and of 17 months for 1968-69.
(3.) The WTO initiated penalty proceedings under Section 18(1)(a) of the W.T. Act and, after hearing the assessee, imposed penalties in the sums of Rs. 4,896 and Rs. 5,663 for these two years, respectively.;