Requirement of furnishing tax audit report under section 44AB was introduced only with effect from 1-7-1995 for purpose of section 271B

ORAL JUDGMENT (PER DR. D.Y. CHANDRACHUD, J.) 1) The petitioner seeks to challenge orders passed by the Commissioner of Income Tax, Kolhapur on 28 September 1995 and on 25 March 1996. By the first of those orders, the Commissioner rejected an application filed by the petitioner under Section 264 questioning the imposition of a penalty on him under Section 271B. By the second of those orders, an application for rectification that was filed by the petitioner was dismissed. 2) The facts in so far as they are relevant fall within a narrow compass. The petitioner filed his return of income for asses...