Penalty liability remains despite prior payment of tax; amendment clarifies that tax payment does not extinguish penalty. Insertion of an Explanation into section 221(1) declaring that payment of the tax before the levy of a penalty does not by itself remove an assessee's liability to any penalty under that sub section.
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Provisions expressly mentioned in the judgment/order text.
Penalty liability remains despite prior payment of tax; amendment clarifies that tax payment does not extinguish penalty.
Insertion of an Explanation into section 221(1) declaring that payment of the tax before the levy of a penalty does not by itself remove an assessee's liability to any penalty under that sub section.
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