JUDGMENT : P.N. Bhagwati, J. This reference raises a very interesting question of law relating to the interpretation of section 271(1)(a) of the Income-tax Act, 1961 (hereinafter referred to as "the new Act"). The facts giving rise to the reference are few and may be briefly stated as follows. The assessee is a registered firm and for the assessment year 1961-62, the assessee was required to furnish its return of income on or before 30th June, 1961, by virtue of the public notice issued by the Income-tax Officer under section 22, sub-section (1) of the Indian Income-tax Act, 1922 (hereinafter referred to as "the old Act"). The date for delivery of the return, namely, 30th June, 1961, was not extended by the Income-tax Officer under the proviso to section 22, sub-section (1), and the assessee should have, therefore, filed its return of the income on or before that date. But the assessee failed to do so and filed its return of income as late as 31st January, 1966. By that time the old Act was repealed and the new Act had taken its place and section 297(2)(b) of the new Act required that since the return of income was filed by the assessee after the commencement of the new Act, the assessment of the assessee for the assessment year 1961-62 should be made in accordance with the procedure specified in the new Act. The return of income being filed before the expiration of four years from the end of the assessment year 1961-62, it was regarded as a voluntary return under section 139, sub-section (4), and the Income-tax Officer processed it and assessed the assessee to tax under section 143. The Income-tax Officer in the course of the assessment proceedings was prima facie satisfied that the assessee had without reasonable cause failed to furnish its return of income within the time allowed by the notice under section 22, sub-section (1) of the old Act and he, therefore, issued a notice under section 274 calling upon the assessee to show cause why penalty should not be levied upon it under section 271(1)(a). The assessee submitted its explanation giving various reasons for late filing of the return, but the Income-tax Officer was not satisfied with the explanation offered by the assessee and he levied a penalty of Rs. 16,415 on the assessee under section 271(1)(a). The assessee submitted its explanation giving various reasons for late filing of the return, but the Income-tax Officer was not satisfied with the explanation offered by the assessee and he levied a penalty of Rs. 16,415 on the assessee under section 271(1)(a). The assessee appealed against the order of penalty to the Appellate Assistant Commissioner but the appeal was unsuccessful. The matter was thereupon carried in further appeal to the Tribunal. There was only one contention urged before the Tribunal, namely, that the return having been filed before the assessment was made and within four years from the end of the assessment year 1961-62 as provided under section 139, sub-section (4), there was no default on the part of the assessee for which penalty could be levied under section 271(1)(a). This contention was accepted by the Tribunal in view of the decision of the Supreme Court in Commissioner of Income-tax v. Kulu Valley Transport Co. P. Ltd. [1970] 77 I.T.R. 518 and the Tribunal held, relying on certain observations in this decision, that the return having been filed before assessment within four years from the end of the assessment year 1961-62 as contemplated under section 139, sub-section (4), it must be deemed to have been filed within the time allowed under section 22, sub-section (1), of the old Act and there was accordingly no default on the part of the assessee within the meaning of section 271(1)(a). The Tribunal in this view of the matter allowed the appeal and set aside the order of penalty. The question is whether this view taken by the Tribunal is correct. 2. It may be pointed out at the outset that though, on the facts of the present case, the default for which penalty was sought to be levied by the revenue was one in respect of section 22, sub-section (1), of the old Act, it was common ground between the parties that the position would be the same as if the default related to non-compliance with section 139, sub- section (1). We will, therefore, proceed to discuss the question before us on the basis that the assessee failed to furnish the return within the time allowed to it under section 139, sub-section (1), but furnished it thereafter, within four years from the end of the assessment year 1961-62, as contemplated under section 139, sub-section (4). We will, therefore, proceed to discuss the question before us on the basis that the assessee failed to furnish the return within the time allowed to it under section 139, sub-section (1), but furnished it thereafter, within four years from the end of the assessment year 1961-62, as contemplated under section 139, sub-section (4). Can the assessee in such a case be said to be guilty of default so as to attract the penalty under section 271(1)(a) ? 3. The answer to the question turns primarily on the true interpretation of two sections of the new Act, section 139 and section 271(1)(a). Section 139 provides for filing a return of income and the material portion of this section reads as under : "139. 3. The answer to the question turns primarily on the true interpretation of two sections of the new Act, section 139 and section 271(1)(a). Section 139 provides for filing a return of income and the material portion of this section reads as under : "139. (1) Every person if his total income.........during the previous year exceeded the maximum amount which is not chargeable to income- tax, shall furnish a return of his income..........during the previous year in the prescribed form and verified in the prescribed manner and setting forth such other particulars as may be prescribed- (a) in the case of every person whose total income......includes any income from business or profession, before the expiry of six months from the end of the previous year.........or before the 30th day of June of the assessment year, whichever is later ; (b) in the case of every other person, before the 30th day of June of the assessment year : Provided that, on an application made in the prescribed manner, the Income-tax Officer may, in his discretion, extend the date for furnishing the return- (i) in the case of any person whose total income includes any income from business or profession the previous year in respect of which expired on or before the 31st day of December of the year immediately preceding the assessment year, and in the case of any person referred to in clause (b), up to a period not extending beyond the 30th day of September of the assessment year without charging any interest ; (ii) in the case of any person whose total income includes any income from business or profession the previous year in respect of which expired after the 31st day of December of the year immediately preceding the assessment year, up to the 31st day of December of the assessment year without charging any interest ; and (iii) up to any period falling beyond the dates mentioned in clauses (i) and (ii), in which case, interest at nine per cent. per annum shall be payable from the 1st day of October or the 1st day of January, as the case may be, of the assessment year to the date of the furnishing of the return- (a) in the case of a registered firm . . . . per annum shall be payable from the 1st day of October or the 1st day of January, as the case may be, of the assessment year to the date of the furnishing of the return- (a) in the case of a registered firm . . . . on the amount of tax which would have been payable if the firm had been assessed as an unregistered firm, and (b) in any other case, on the amount of tax payable on the total income, reduced by the advance tax, if any, paid or by any tax deducted at source, as the case may be . . . . (2) In the case of any person who, in the Income-tax Officer's opinion, is assessable under this Act . . . . . the Income-tax Officer may, before the end of the relevant assessment year, serve a notice upon him requiring him to furnish, within thirty days from the date of service of the notice, a return of his income . . . . in the prescribed manner and setting forth such other particulars as may be prescribed : Provided that on an application made in the prescribed manner the Income-tax Officer may, in his discretion, extend the date for the furnishing of the return, and when the date for furnishing the return, whether fixed originally or on extension, falls beyond the 30th day of September or, as the case may be, the 31st day of December of the assessment year, the provisions of sub-clause (iii) of the proviso to sub-section (1) shall apply. (3) If any person who has not been served with a notice under sub- section (2), has sustained a loss in any previous year under the head "Profits and gains of business or profession" or under the head "Capital gains" and claims that the loss or any part thereof should be carried forward under sub-section (1) of section 72, or sub-section (2) of section 73, or sub-section (1) of section 74, he may furnish, within the time allowed under sub-section (1), a return of loss in the prescribed form and verified in the prescribed manner and containing such other particulars as may be prescribed, and all the provisions of this Act shall apply as if it were a return under sub-section (1). (4) (a) Any person who has not furnished a return within the time allowed to him under sub-section (1) or sub-section (2) may, before the assessment is made, furnish the return for any previous year at any time before the end of the period specified in clause (b), and the provisions of clause (iii) of the proviso to sub-section (1) shall apply in every such case ; (b) the period referred to in clause (a) shall be- (i) where the return relates to a previous year relevant to any assessment year commencing on or before the 1st day of April, 1967, four years from the end of such assessment year ; . . . . (5) If any person having furnished a return under sub-section (1) or sub-section (2), discovers any omission or any wrong statement therein, he may furnish a revised return at any time before the assessment is made." 4. Section 271 provides for imposition of penalty in various circumstances. We are concerned here only with sub-section (1)(a) of this section which is in the following terms : "271. (1) If the Income-tax Officer or the Appellate Assistant Commissioner in the course of any proceedings under this Act, is satisfied that any person- (a) has without reasonable cause failed to furnish the return of total income which he was required to furnish under sub-section (1) of section 139 or by notice given under sub-section (2) of section 139 or section 148 or has without reasonable cause failed to furnish it within the time allowed and in the manner required by sub-section (1) of section 139 or by such notice, as the case may be, or . . . . he may direct that such person shall pay by way of penalty,- (i) in the cases referred to in clause (a), in addition to the amount of the tax, if any, payable by him, a sum equal to two per cent. of the tax for every month during which the default continued, but not exceeding in the aggregate fifty per cent. of the tax ; . . . . . " 5. The argument of the revenue based on the language of these provisions was that the main part of section 139, sub-section (1), required an assessee to file his return of income and allowed him a certain definite time within which he must do so. of the tax ; . . . . . " 5. The argument of the revenue based on the language of these provisions was that the main part of section 139, sub-section (1), required an assessee to file his return of income and allowed him a certain definite time within which he must do so. The proviso to section 139, sub-section (1), empowered the Income-tax Officer to extend the time for filing the return. If the return was filed within the time specified in the main part of section 139, sub-section (1), or within the extended time, in case the time was extended by the Income-tax Officer under the proviso, the return would be within the time allowed to the assessee under section 139, sub-section (1), and the Income-tax Officer would be bound to act on the return and make the assessment under section 143. But even if the assessee failed to furnish the return within the time allowed under section 139, sub-section (1), and committed default, he could still avail of section 139, sub-section (4), and file his return under that sub-section so long as he did so before the assessment was made and within four years from the end of the assessment year. Such a return would be a valid return and the Income-tax Officer would be bound to process it for the purpose of assessment under section 143. That, however, would not absolve the assessee of the default committed by him in failing to furnish the return within the time allowed to him under section 139, sub-section (1). The default would fall fairly and squarely within the plain language of section 271(1)(a) and would be punishable by imposition of penalty under that provision. The revenue conceded that the first part of section 271(1)(a) would not apply in the present case since a valid return was filed by the assessee under section 139, sub-section (4), but the second part of the section was clearly, in the submission of the revenue, applicable, because the assessee had without reasonable cause failed to furnish a return within the time allowed under section 139, sub- section (1), and furnished it only under section 139, sub-section (4), after the expiration of such time. The assessee was, therefore, said the revenue, liable to penalty under the second part of section 271(1)(a). The assessee was, therefore, said the revenue, liable to penalty under the second part of section 271(1)(a). The assessee, on the other hand, urged that sub-section (4) was in the nature of a proviso to sub-section (1) of section 139 ; it had the effect of extending the time specified in section 139, sub-section (1). Therefore, if the assessee filed the return in conformity with section 139, sub-section (4), he should be deemed to have filed his return within the time allowed under sub-section (1) of section 139 and section 271(1)(a) would not be attracted. This contention was staked on certain observations in the decision of the Supreme Court in Commissioner of Income-tax v. Kulu Valley Transport Co. P. Ltd. [1970] 77 I.T.R. 518 and the strongest reliance was placed upon them. The question is which of these rival contentions should be accepted. We now proceed to consider that question. 6. We will first proceed to examine the question on principle, uninfluenced by any judicial decisions, because, as pointed out by Warrington L.J. : "The safer and more correct course of dealing with a question of construction is to take the words themselves and arrive, if possible, at their meaning without, in the first place, reference to cases." (Barrell v. Fordree [1932] A.C. 676, 682 (H.L.). 7. We would prefer to avoid exegesis of the statutory language unless they are absolutely necessary, for the result would otherwise tend thereafter to substitue for the problem of construction of parliamentary language the problem of the construction of the judgments of the courts. Vide Lord Evershed M.R. in Bewlay (Tobacconists) Ltd. v. British Bata Shoe Co. Ltd. [1959] 1 W.L.R. 45 (C.A.). The first section which calls for consideration is section 139 which provides for filing of the return of income by an assessee. Sub-section (1) of section 139 requires every person whose total income during the previous year exceeds the maximum amount which is not chargeable to income-tax, to furnish a return of income in the prescribed form on or before a certain specified date. Sub-section (1) of section 139 requires every person whose total income during the previous year exceeds the maximum amount which is not chargeable to income-tax, to furnish a return of income in the prescribed form on or before a certain specified date. This date for furnishing the return specified in section 139, sub-section (1), is, however, not unalterable, because power is conferred on the Income-tax Officer by the proviso to grant extension of time for filing a return up to 30th day of September, or 31st day of December, according as the case falls within clause (i) or clause (ii) of the proviso, without charging any interest and beyond these dates, upon payment of interest at the rate of nine per cent. per annum. If, therefore, an assessee finds that he is unable to file his return of income before the date specified in section 139, sub-section (1), he can apply for extension of time to the Income- tax Officer and the Income-tax Officer may, in his discretion, grant extension of time to him without charging any interest or upon payment of interest at the rate of nine per cent. per annum depending upon the date to which time is extended by the Income-tax Officer. The assessee must file his return of income before the date specified in sub-section (1) of section 139 or within the extended time, if extension of time has been granted by the Income-tax Officer, and if he does so, his return of income would be clearly within the time allowed under sub-section (1) of section 139. 8. The Income-tax Officer may also, in the case of any person who in his opinion is assessable under the Act, serve upon him notice under section 139, sub-section (2), requiring him to furnish a return of his income within thirty days from the date of service of the notice upon him. This notice may be served at any time but before the end of the assessment year. If the assessee is unable to file his return of income within thirty days from the date of service of the notice upon him, he may apply for extension of time under the proviso to sub-section (2) of section 139, and the Income-tax Officer may, in his discretion, extend the date for furnishing the return, subject to the provisions of sub-clause (iii) of the proviso to sub-section (1) of section 139. The assessee must file his return of income within thirty days from the date of service of the notice upon him or within the extended time, if extension of time has been granted and if he does so, the return of income filed by him would be within the time allowed to him under section 139, sub-section (2). 9. But even if the assessee has not furnished a return of income within the time allowed to him under sub-section (1) or sub-section (2) of section 139 which would include time extended under the proviso to either sub- section and committed default in complying with the obligation under these sub-sections, the assessee is given locus poenitentiae under section 139, sub- section (4), and he may still file a return of income at any time before the expiration of four years from the end of the assessment year, provided the assessment is not yet made. Of course, if the assessment is already made, there can be no question of filing a return. The assessment in such a case would be a best judgment assessment under section 144. It may be noted that no assessment can be made on a person who fails to make a return within the time allowed under sub-section (1) of section 139 unless a notice under section 139, sub-section (2), is served upon him. It is only if he fails to file a return in response to the notice under sub-section (2) of section 139 that the Income-tax Officer can proceed to make a best judgment assessment under section 144. But so long as the best judgment assessment is not made, the assessee can always file a return within four years from the end of the assessment year. Such a return would be a valid return under section 139, sub-section (4). 10. It will thus be seen that section 139 contemplates filing of a return by an assessee at any one of three different stages. The return may be filed within the time allowed under sub-section (1) or where notice has been issued by the Income-tax Officer under sub-section (2) within the time allowed under that sub-section or, even thereafter, under sub-section (4) provided it is done within four years from the end of the assessment year and before the assessment is made. The return may be filed within the time allowed under sub-section (1) or where notice has been issued by the Income-tax Officer under sub-section (2) within the time allowed under that sub-section or, even thereafter, under sub-section (4) provided it is done within four years from the end of the assessment year and before the assessment is made. The return of income filed at any of these three stages would be a valid return under section 139 and the Income-tax Officer would be bound to process it and make assessment under section 143. But once the period of four years from the end of the assessment year has expired, there is no provision in the new Act under which return of income can be filed by the assessee. The only provision in the new Act which provides for filing of a return of income is section 139 and that does not contemplate any return of income which may be filed after the expiration of four years from the end of the assessment year. If a return of income is purported to be filed after the expiration of four years from the end of the assessment year, it would be a mere scrap of paper without any legal consequence. It would indeed be a misnomer to call it a return of income, because there is no provision of law under which it could be filed. It would not be a return in the eye of the law. 11. We may now turn to examine the language of section 271(1)(a) which is the section which primarily falls for interpretation. Section 271(1)(a) consists of two clauses : each clause sets out the ingredients which, if fulfilled, would immediately attract penalty. The first clause refers to a case where a person has without reasonable cause failed to furnish the return of total income which he was required to furnish under sub-section (1) of section 139, or by notice given under sub-section (2) of section 139, or section 148, while the second applies to a case where a person has without reasonable cause failed to furnish the return of income within the time allowed and in the manner required by sub-section (1) of section 139, or by notice given under sub-section (2) of section 139, or section 148. The question is : what is the true scope and ambit of these clauses ? The question is : what is the true scope and ambit of these clauses ? We are, of course, concerned here only with the second clause but it is elementary that no one part of a statutory provision can be construed in isolation. The court is entitled, and indeed bound, when construing the terms of any provision found in a statute, to consider any other parts of the statute which throw light on the intention of the legislature, and which may serve to show that a particular provision ought not to be construed as it would be alone and apart from the rest of the Act. This principle of construction would apply with greater vigour where there are two clauses in a statutory provision and one of them is required to be construed by the court. Each clause must in such a case be construed with reference to the other clause so as, as far as possible, to make a consistent enactment of the whole statutory provision. We must, therefore, proceed to construe the second clause in the light of the provision enacted in the first and read the two clauses together to arrive at a proper meaning of the second clause. We must also have regard to the context and the setting in which the second clause occurs in order to determine its true meaning and import. It is true, and there we agree with the learned Advocate-General appearing on behalf of the assessee, that the statutory provision enacted in section 271(1)(a) is punitive in its effect and must, therefore, be strictly construed. But that does not mean that it should be narrowly or stintingly understood or that we should refuse to place upon it a construction which its words would reasonably seem to bear. The principle of strict construction requires no more than this that we must exclude from the ambit and operation of the statutory provision all that is not clearly covered by the words used. The coverage of the statutory provision must be confined to that which is clear and explicit and we must not be over-anxious to place a construction which would expand the scope and ambit of the statutory provision. Bearing in mind well-settled rules of interpretation, we will now proceed to examine the language of section 271(1)(a). 12. The coverage of the statutory provision must be confined to that which is clear and explicit and we must not be over-anxious to place a construction which would expand the scope and ambit of the statutory provision. Bearing in mind well-settled rules of interpretation, we will now proceed to examine the language of section 271(1)(a). 12. It is obvious on a plain reading of the language of section 271(1)(a) that the two clauses of the section deal with two different situations. The first clause deals with a situation where a person has, without reasonable cause, failed to furnish a return of income which he was required to furnish under sub-section (1) of section 139, or by notice given under sub-section (2) of section 139, or section 148. That would be a case where no return of income has been filed by a person though required to do so under sub- section (1) of section 139, or by notice given under sub-section (2) of section 139, or section 148. Where there is failure to file the return of income altogether without reasonable cause such default would be covered by the first clause. The second clause deals with a different situation where there is no failure to furnish the return of income altogether but the return of income has been furnished outside the time allowed under sub- section (1) of section 139, or by notice given under sub-section (2) of section 139, or section 148. The emphasis in the second clause on failure to furnish the return of income within the time allowed in contradistinction to failure to furnish the return of income referred to in the first clause clearly indicates that the first clause is intended to cover a case where the assessee has failed to furnish any return of income at all while the second clause is intended to apply to a case where a return of income is furnished by the assessee, but it is late in the sense that it is not furnished within the time allowed under sub-section (1) of section 139, or by notice given under sub-section (2) of section 139, or section 148. The first clause deals with the case of non-filing of return of income while the second deals with the case of late filing of the return. The first clause deals with the case of non-filing of return of income while the second deals with the case of late filing of the return. This is the only construction possible on a combined reading of the two clauses of section 271(1)(a). Any other construction would fail to give due effect to the words "within the time allowed" in the second clause and render one or the other of the two clauses superfluous. So far, there was no dispute between the parties but the controversy arose as to what was the true meaning of the expression "within the time allowed . . . . by sub-section (1) of section 139" in the second clause. The assessee contended that sub-section (4) of section 139 was in the nature of a proviso to sub-section (1) of section 139, and, therefore, when the assessee filed his return of income within four years from the end of the assessment year as contemplated under section 139, sub-section (4), the assessee must be held to have filed his return of income within the time allowed under sub-section (1) of section 139. The expression "within the time allowed . . . by sub-section (1) of section 139", according to the assessee, included the time within which a return of income may be filed by the assessee under sub-section (4) of section 139. We do not think this construction is warranted by the language of the second clause. The second clause uses the words "within the time allowed . . . . . by sub- section (1) of section 139", and these words, according to their plain natural meaning, must be taken to refer to the time specified in sub-section (1) of section 139, or extended by the Income-tax Officer under the proviso to that sub-section. It is a well-settled rule of interpretation that where the words of a statutory enactment are clear and explicit, the court must construe them in their ordinary natural sense, unless of course there is something in the context which compels the court to adopt a different construction. Here, not only there is nothing in the context to indicate that the legislature intended to use the words "within the time allowed . . . . . Here, not only there is nothing in the context to indicate that the legislature intended to use the words "within the time allowed . . . . . by sub-section (1) of section 139", as including the time within which return of income may be filed under section 139, sub-section (4), but, as we shall presently show, the context clearly gives a contrary indication and there is no reason why we should add anything to the words used by the legislature or read them in a sense different from their ordinary grammatical sense. 13. If the legislature intended that a person should be punishable under the second clause, only if he failed to furnish a return of income within a period of four years from the end of the assessment year, there is no reason why the legislature should have used the words "within the time allowed . . . . by sub-section (1) of section 139". The legislature could have very well said that if a person without reasonable cause fails to furnish the return of income within four years from the end of the assessment year, he shall be liable to penalty. But the legislature deliberately and advisedly used the words "within the time allowed.......by sub-section (1) of section 139". That is a clear indication that the legislature did not intend that failure to furnish the return of income within four years from the end of the assessment year should be an offence under the second clause, for it is a well-settled rule of construction of statutes that if there are two expressions which might have been used to convey a certain intention, but one of those expressions will convey that intention more clearly than the other, it is proper to conclude that, if the legislature uses that one of the two expressions which would convey the intention less clearly, it does not intend to convey that intention at all. Vide Craies on Statute Law, seventh edition, page 92. Moreover, it is difficult to appreciate why the legislature should have provided that if an assessee does not furnish the return of income at all even after the expiration of four years, he should be liable to penalty under the first clause but if he furnishes the return of income after the expiration of four years, he should be liable to penalty under the second clause. The filing of the return of income after the expiration of four years has no meaning and is wholly futile and it is difficult to imagine why a mere factual filing of the return of income which has no legal consequence and which is nothing but an exercise in futility should have been made a basis of distinction for the purpose of enactment of two different clauses in section 271(1)(a). Furthermore, it is evident that when the first clause says that a person shall be liable to penalty under that clause, if he has, without reasonable cause, failed to furnish a return of income which he was required to furnish under sub-section (1) of section 139, it must have reference only to furnishing of return of income as contemplated under the new Act. The return of income which a person is required to furnish under sub-section (1) of section 139 may be furnished within the time allowed under sub-section (1) of section 139, or even thereafter under section 139, sub-section (4). But, as pointed out above, no return of income can be furnished by any person after the expiration of four years from the end of the assessment year. Such a return furnished after the expiration of four years from the end of the assessment year would not be a return contemplated under the new Act and an assessee cannot resist the first clause by saying that he has not failed to furnish the return of income which he was required to furnish under sub-section (1) of section 139, because he has furnished what is an invalid return, a return not contemplated by the new Act, a return which is no return in the eye of the law. When the first clause speaks of failure to furnish return of income, it has obviously reference to section 139, which provides for furnishing of return of income and it is with reference to the provisions of section 139, that it must be judged whether there is failure to furnish the return of income. When the first clause speaks of failure to furnish return of income, it has obviously reference to section 139, which provides for furnishing of return of income and it is with reference to the provisions of section 139, that it must be judged whether there is failure to furnish the return of income. Where the assessee furnishes the return of income after the expiration of four years from the end of the assessment year, the return of income so furnished would be no return at all within the contemplation of section 139, and, therefore, it would be logically correct to say that the assessee has failed to furnish the return of income and if that be so, he would be liable to penalty under the first clause. But, then, the second clause would be rendered superfluous because, on the construction contended for on behalf of the assessee, the second clause would also cover the same kind of cases as the first clause, namely, cases where the assessee fails to furnish the return of income within four years from the end of the assessment year. There would be complete overlapping of the two clauses and the second clause would become wholly redundant. The court would be slow to reach such a result. The same infirmity would also arise even if we look at the two clauses of section 271(1)(a) from a slightly different view-point. If the construction contended for on behalf of the assessee were accepted the assessee who fails to furnish a return of income within four years from the end of the assessment year would be liable to penalty under the second clause but in that event there would be no reason for the legislature to provide penalty under the first clause, because it would be entirely immaterial whether the assessee furnishes the return of income after the expiration of four years from the end of the assessment year ; if he does so, it would be a futile action with no legal consequence and, moreover, it would be meaningless to save him from the penalty under the first clause, because the penalty under the second clause which has been incurred by him would remain unaffected and if he fails to do so, there would be no point in imposing on him a second penalty under the first clause. It will, therefore, be seen that there is inherent evidence in the language of section 271(1)(a) itself which shows that the legislature used the words "within the time allowed . . . by sub-section (1) of section 139", in their ordinary natural sense and not so as to include the time within which the return of income may be filed under sub-section (4) of section 139. It is only on this interpretation that we can give full meaning and effect to both clauses of section 271(1)(a). 14. We may also refer to the opening words of section 139, sub-section (4), namely, "any person who has not furnished a return within the time allowed to him under sub-section (1) or sub-section (2)". These words clearly postulate default in furnishing return strictly within the time allowed under sub-section (1) or sub-section (2) of section 139, and provide that, even though a person has made such default he may file a return of income within four years from the end of the assessment year, provided that the assessment is not already made. The object of giving locus poenitentiae to an assessee is that, so long as the assessment is not made, he may file a return of income and if he files it, the Income-tax Officer would be bound to process it and make assessment under section 143. But that does not mean that the assessee ceases to be liable for the other consequences of the default. But for sub-section (4) of section 139, the assessee would not have been able even to file a return of income after the expiration of the time allowed to him under sub-section (1) or sub section (2) of section 139. That would have caused great hardship to the assessee for it would have enabled the Income-tax Officer to make best judgment assessment which might be highly prejudicial to the assessee. The legislature, therefore, gave one more opportunity to the assessee to file a return of income despite the default committed by him. But, if the default committed by him attracted any other consequences, they were not obliterated by sub-section (4) of section 139. The legislature, therefore, gave one more opportunity to the assessee to file a return of income despite the default committed by him. But, if the default committed by him attracted any other consequences, they were not obliterated by sub-section (4) of section 139. There is no doubt that sub- section (4) of section 139 has to be read with sub-section (1) of section 139, so as to permit the filing of a valid return, whether of income, profits or gains or of loss, but it cannot be construed so as to wipe out the limit of time referred to in sub-section (1) of section 139 altogether and for all purposes. If such was the intention of the legislature, the legislature need not have prescribed the time limit in sub-section (1) of section 139. The prescription of the time limit in sub-section (1) of section 139 would be an exercise in futility. It would have no sanction behind it, because even if an assessee does not file a return of income within such time limit, the assessee would be free from harm, because the Income-tax Officer would not be able to impose any penalty on him nor would he be able to make a best judgment assessment without issuing notice under section 139, sub- section (2). That surely could not have been the intention of the legislature. Such a construction would emasculate sub-section (1) of section 139, and make a mockery of the time limit specified in sub-section (1) of section 139. The same argument must apply also in relation to the time limit specified in the notice given under section 139, sub-section (2). It may also be noted that the words of the second clause of section 271(1)(a) are almost identical with the opening words of section 139, sub-section (4), which admittedly refer to default in furnishing return within the time allowed under sub- section (1) or sub-section (2) of section 139, without reference to section 139, sub-section (4) and, therefore, it is reasonable to assume that when the legislature used almost the same words in the second clause of section 271 (1)(a), the legislature intended them to have the same meaning. The time within which return of income may be filed under section 139, sub-section (4), cannot, therefore, be projected in the second clause of section 271(1). 15. The time within which return of income may be filed under section 139, sub-section (4), cannot, therefore, be projected in the second clause of section 271(1). 15. The learned Advocate-General, appearing on behalf of the assessee, objected to this construction of the second clause of section 271(1)(a) on the ground that it would result in double penalty. If a person files his return of income after the time allowed under sub-section (1) or sub-section (2) of section 139 but before the expiration of four years from the end of the assessment year, he would be liable to pay "penal interest" under clause (iii) of the proviso to sub-section (1) and he would also be liable to pay penalty under the second clause of section 271(1)(a). The legislature could not have intended to impose such double penalty for the same default. We do not think this objection is well founded. It suffers from several defects. In the first place, it is not correct to say that interest chargeable to a person who files his return of income under section 139, sub-section (4), is "penal interest", though that is an expression which is commonly in use in income-tax parlance. It is not by way of penalty that interest is chargeable from a person who does not file his return within the time allowed to him under sub-section (1) of section 139. If we look at clause (iii) of the proviso to sub-section (1) of section 139, it is clear that even where the Income-tax Officer grants extension of time to a person to file his return of income, the person to whom extension of time is granted is liable to pay interest, if the extended date falls beyond a particular date. There is no question in such a case of levying any penalty on the person concerned, because extension of time having been granted to him, he is not in default. Interest is not charged to him by way of penalty but he is required to pay it, because by reason of extension of time, the filing of the return would be delayed and that would in its turn delay the assessment and consequent realisation of tax from the assessee. It is, therefore, by way of compensation for delay in realisation of tax that interest is required to be paid by the assessee. It is, therefore, by way of compensation for delay in realisation of tax that interest is required to be paid by the assessee. Now, obviously, if a person who obtains extension of time beyond a certain date is required to pay interest, a person who does not seek extension of time but files the return of income under sub-section (4) of section 139 after the time specified in sub-section (1) of section 139 cannot be allowed to escape payment of interest. The latter cannot be placed in a better position than the former and, therefore, with a view to putting the latter on par with the former in this respect, the legislature made the provision in clause (iii) of the proviso to sub- section (1) applicable in a case where a person files his return of income under section 139, sub-section (4). This interest which a person filing his return under section 139, sub-section (4), is required to pay is thus not by way of penalty but it is only by way of compensation for delay in realisation of tax. It is very much different from the penalty for default in furnishing return of income within the time allowed under sub-section (1) or sub-section (2) of section 139. There is, therefore, no question of imposition of double penalty on the interpretation contended for on behalf of the revenue. 16. This view which we are taking is supported by two decisions, one an unreported decision given by the Andhra Pradesh High Court on 19th February, 1971, in Reference Case No. 71 of 1961 Purna Biscuit Factory v. Commissioner of Income-tax (R.C. No. 71 of 1968-19-2-71-unreported) and the other, a decision of the Madras High Court in K.C. Vedadri v. Commissioner of Income-tax [1973] 87 I.T.R. 76 (Mad.). But it was strenuously urged by the learned Advocate-General on behalf of the assessee that whatever be the merits of this view which we are inclined to take as a matter of plain construction, it was wholly unsustainable in view of the decision of the Supreme Court in Commissioner of Income-tax v. Kulu Valley Transport Co. (P.) Ltd. [1970] 77 I.T.R. 518. The strongest reliance was placed on this decision and the case was almost entirely rested on the observations made in this decision and it is, therefore, necessary to examine this decision in some detail. (P.) Ltd. [1970] 77 I.T.R. 518. The strongest reliance was placed on this decision and the case was almost entirely rested on the observations made in this decision and it is, therefore, necessary to examine this decision in some detail. The question which arose for decision before the Supreme Court in this case was whether a loss return having been filed by the assessee after the time specified in the general notice given under sub-section (1) of section 22 of the old Act, the revenue was bound to determine the loss and allow it to be carried forward under section 24(2) of the old Act. The judges were divided in opinion on this question and the majority took the view that the Income-tax Officer was bound to determine the loss returned by the assessee and to allow it to be carried forward after being set off under section 24(2). Grover J., speaking on behalf of the majority, pointed out that the question which was submitted for opinion consisted of two parts, namely, (1) whether the loss returned by the assessee was required in law to be determined by the Income-tax Officer ; and (2) whether it could be carried forward after being set off under section 24(2) of the Act. The first part of the question raised the point whether a loss return could be filed by an assessee under section 22, sub-section (3). The argument was that since the public notice under section 22, sub-section (1) required only a person whose total income during the previous year exceeded the maximum amount not chargeable to tax, to furnish a return of income, a loss return was not within the contemplation of section 22, sub-section (1), and a fortiori, it could not be furnished under section 22, sub-section (3), and the Income-tax Officer was, therefore, not bound to determine the loss returned by the assessee. This argument was negatived by Grover J. on the ground that it stood concluded by the decision of the Supreme Court in Commissioner of Income-tax v. Ranchhoddas Karsondas [1959] 36 I.T.R. 569 Grover J., pointed out that it was decided by the Supreme Court in Ranchhoddas Karsondas's case [1959] 36 I.T.R. 569 that a return showing income below taxable limit could be made in answer to a public notice under section 22, sub-section (1), and also under section 22, sub-section (3), and this statement of the law would apply equally to a case of loss return. The learned judge then proceeded to add- "The amendment in 1953", that is, the amendment which introduced sub-section (2A) in section 22 : "seems to have been made to clarify the law about the filing of a return showing a loss voluntarily. It was declared that such a return could be validly made. The time which was specified for filing the return was on the same lines as in sub-section (1) of section 22, and all the provisions of the Act were to apply as if it was a return under sub-section (1)." 17. The object of introducing section 22, sub-section (2A), was not to add anything to the section which was not there but to clarify that a loss return could be validly made within the time specified in the general notice given under sub-section (1) of section 22 and all the provisions of the old Act would apply as if it were a return under sub-section (1) of section 22. Grover J. accordingly held that the Income-tax Officer was not entitled to ignore the loss return and was bound to determine the loss returned by the assessee. Having thus disposed of the first part of the question, Grover J. proceeded to consider the second part and, while dealing with the second part, he made the following observations which are strongly relied upon on behalf of the assessee [1970] 77 I.T.R. 518, 529 ; [1971] 1 S.C.R.452 (S.C.). : "Section 24(2) confers the benefit of losses being set off and carried forward and there is no provision in section 22 under which losses have to be determined for the purpose of section 24(2). The question which immediately arises is whether section 22(2A) places any limitation on that right. : "Section 24(2) confers the benefit of losses being set off and carried forward and there is no provision in section 22 under which losses have to be determined for the purpose of section 24(2). The question which immediately arises is whether section 22(2A) places any limitation on that right. This sub-section which has been reproduced before simply says that in order to get the benefit of section 24(2) the assessee must submit his loss return within the time specified by section 22(1). That provision must be read with section 22(3) for the purpose of determining the time within which a return has to be submitted. It can well be said that section 22(3) is merely a proviso to section 22(1). Thus, a return submitted at any time before the assessment is made is a valid return. In considering whether a return made is within time, sub-section (1) of section 22 must be read along with sub-section (3) of that section. A return whether it is a return of income, profits or gains or of loss must be considered as having been made within the time prescribed if it is made within the time specified in section 22(3). In other words, if section 22(3) is complied with, section 22(1) also must be held to have been complied with. If compliance has been made with the latter provision the requirements of section 22(2A) would stand satisfied." 18. These observations read superficially might seem to support the contention of the assessee, but if we examine them closely, it will be apparent that they do not lay down any absolute proposition which can be applied in all situations where the question of examining time limit arises. We have had occasion to say before, and we repeat here once again, that when we are considering the pronouncements of the highest judicial authority, the greatest possible care must be taken to relate the observations of a judge to the precise issues before him and to confine such observations, even though expressed in broad terms, to the general compass of the question before him, unless he makes it clear that he intended his remarks to have a wider ambit. It is not possible for judges always to express their judgments so as to exclude entirely the risk that in some subsequent case their language may be mis-applied and any attempt at such perfection of expression can only lead to the opposite result of uncertainty or even obscurity as regards the case in hand. Moreover, it is well settled that a decision is an authority only for what it decides. It cannot be extended by analogy or inference to govern a totally different situation. In Kulu Valley Transport Company's case [1970] 77 I.T.R. 518, the Supreme Court was concerned only with the limited question, namely, whether on a proper interpretation of section 22, sub-section (2A), an assessee was entitled to set off and carry forward of loss under section 24, sub-section (2), if he filed a loss return after the time allowed under sub-section (1) of section 22 but before the expiration of four years from the end of the assessment year under section 22, sub-section (3). The argument of the revenue was that the words "within the time specified in the general notice given under sub- section (1) or within such time as the Income-tax Officer in any case may allow" in section 22, sub-section (2A), restricted the right of set-off and carry-forward of loss to a case where a loss return was filed strictly within the time specified in the general notice given under section 22, sub- section (1), or within the extended time, but if it was filed after the expiration of such time, the condition of these words would not be satisfied and set-off and carry-forward of loss would not be admissible. This argument was repelled by Grover J., stating that section 22, sub-section (2A), was merely clarificatory. It did not add anything to section 22 nor take away anything from it. Even without it, a loss return could be filed by an assessee within the time allowed under section 22, sub-section (1), as also under section 22, sub-section (3), and if such return was filed, the Income-tax Officer would be bound to determine the loss and allow it to be set off and carried forward under section 24, sub-section (2). Sub-section (2A) was introduced in section 22 merely with a view to clarifying this position. Sub-section (2A) was introduced in section 22 merely with a view to clarifying this position. It was not intended to alter the law against the assessee by providing that in order to be entitled to the benefit of set-off and carry-forward of loss, the assessee must file a loss return within the time strictly allowed under sub- section (1) of section 22 and if he failed to do so, he should be dis entitled to such benefit. It was in this context that Grover J. made the aforesaid observations interpreting section 22, sub-section (2A). It is difficult to see how these observations made in the context of section 22, sub-section (2A), can be applied blindly and mechanically, when we are interpreting a wholly different section in a totally different context. It is unsafe and contrary to logic and reason to try to interpret the words used in one statutory provision by reference to the interpretation placed on similar words in another statutory provision. It must be remembered, as pointed out by that great American judge Learned Hand : "The meaning of a sentence may be more than that of the separate words as a melody is more than the notes and no degree of particularity can ever obviate recourse to the setting in which all appear and which all collectively create." 19. Mr. Justice Holmes said : "'A word', and we would add, 'a phrase' is not a crystal, transparent and unchanged ; it is the skin of a living thought and may vary greatly in colour and content according to the circumstances and the time in which it is used." 20. An interpretation given by the Supreme Court in the context of one section cannot be projected in another section, regardless of the context and purpose of that other section. The decision of the Supreme Court is undoubtedly law of the land and with great respect we are bound to follow it. It is farthest from our mind to disregard it or to attempt to distinguish it by indulging in any over-refined subtleties. But we cannot extend it to the interpretation of another section which is wholly different in its context, setting, purpose and intendment. That would be nothing short of refusal on our part to give effect to the intention of the legislature as expressed in the words used in the section. But we cannot extend it to the interpretation of another section which is wholly different in its context, setting, purpose and intendment. That would be nothing short of refusal on our part to give effect to the intention of the legislature as expressed in the words used in the section. We must interpret the language employed by the legislature in its contextual setting having regard to the purpose which the legislature had in mind and, if we do so, it is clear that the second clause of section 271(1)(a) applies where a person fails to furnish a return of income within the time allowed strictly under sub-section (1) or sub-section (2) of section 139 and filing of return after the expiration of such time but before the expiration of four years from the end of the assessment year under section 139, sub-section (4), does not save him from penalty for the default contemplated under the second clause of section 271(1)(a). 21. We, therefore, answer the question referred to us in the negative. The assessee will pay the costs of the reference to the Commissioner.