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<h1>Assessee can challenge liability, not quantum, of penal interest under Income-tax Act</h1> The High Court of Bombay held that the assessee could not appeal against the quantum of penal interest but could challenge the liability to pay such ... Export Market Development Allowance The High Court of Bombay delivered a judgment on a case involving questions of law under the Income-tax Act, 1961 for the assessment year 1971-72. The court ruled that the assessee cannot appeal against the quantum of penal interest charged but can appeal if denying liability to pay such interest. The questions raised by the Department were answered in favor of the assessee based on a previous court judgment.