COMMISSIONER OF INCOME-TAX, DELHI vs S.TEJA SINGH

The Supreme Court held that under Section 18A(9) of the Indian Income-tax Act, 1922, a failure to send an estimate of tax under Section 18A(3) is deemed equivalent to failing to furnish a return of total income under Section 22. Consequently, the Income-tax Officer is competent to impose a penalty under Section 28 for such failure. The Court upheld the imposition of penalty for the assessment years 1948-49 and 1949-50, reversing the decisions of the Appellate Tribunal and the High Court.