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When the appellant is a Govt. corporation, who paid entire tax demand (through may be some interest still remains payable as it was not quantified by the Revenue), before issue of SCN and where ‘intention to evade payment of tax’ cannot be alleged, then in the light of provisions of Section 73(3) and Section 80 of FA, 1994, no penalty is liable to be imposed on the assessee appellant - AT
When the appellant is a Govt. corporation, who paid entire tax demand (through may be some interest still remains payable as it was not quantified by the Revenue), before issue of SCN and where ‘intention to evade payment of tax’ cannot be alleged, then in the light of provisions of Section 73(3) and Section 80 of FA, 1994, no penalty is liable to be imposed on the assessee appellant - AT
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