R.K. Agrawal, J. - (1.) The Income-tax Appellate Tribunal, Allahabad, has referred the following question of law under Section 27(1) of the Wealth-tax Act, 1957 (hereinafter referred to as "the Act"), for opinion to this Court : Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that the asses-see was liable to penalty under the provisions of Section 18(1)(c) of the Wealth-tax Act, 1957, read with Explanation 4 to Section 18(1)(c) of the Wealth-tax Act, 1957, despite the Press Note dated May 27, 1968, issued by the Ministry of Finance and Circular No. 8-WT dated November 15, 1968, issued by the Central Board of Direct Taxes ?
(2.) The reference relates to the assessment years 1979-80 and 1980-81 in the proceedings arising out of penalty imposed under Section 18(1) (c) of the Act.
(3.) Briefly stated, the facts giving rise to the present reference are as follows :;