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of Penalty imposed u/s. 221 r.w.s. 140A(3) - no self assessment tax was paid - the assessee shall not cease to be liable to any penalty under sub-section (1) of section 221 merely by reason of the fact that the assessee paid tax, but however taking into consideration the facts of circumstances, it is fair and just to restrict the penalty to the 1% of the tax amount - AT
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