$ 0 0 In a setback for Jayalalithaa, the Supreme Court has dismissed her appeal against prosecution by income tax department for not filing tax returns from 1991-94. The SC on Thursday allowed the trial court to proceed against Jayalalithaa. The central government through the income tax department had filed a criminal complaint in 1996 under Section 35-B of the Wealth Tax Act, alleging that Jayalalithaa had failed to file returns in due time for the assessment year 1993-1994. In spite of statutory notice, she "willfully and deliberately" failed to file returns, resulting in an ex-parte assessment order, it said.