T.K.Basu, J. - (1.) In this application the petitioner challenges three notices dated the 21st April, 1964, the 13th December, 1965 and the 21st December, 1965 for imposition of penalty issued under the provisions of Section 274 read with Section 271 of the Income-tax Act, 1961. The assessment was made under the provisions of the Indian Income-tax Act 1922, now repealed.
(2.) Mr. Siddharta Roy appearing on behalf of the petitioner contends that this point is concluded in favour of the petitioner by my judgment in the case of Narendra Sharma v. Income-tax Officer, Central Circle 15, Calcutta, Matter No. 213 of 1966 (Cal).
(3.) Counsel for the Revenue submitted before me that there are certain aspects of the matter which have not been considered by me in my above judgment. Considering the importance of the subject-matter, I gave leave to the Revenue to agitate these points in this application.;