Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
221(1) there is in terms a reference to a continuing default and the section empowers the Assessing Officer to levy penalty from time to time, so, however, that the total amount of penalty does not exceed the amount of tax in arrears. Section 201(1A), however, is not couched in similar terms as the other two sections referred