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of Levy of personal penalty - Levy of penalty of ₹ 1 Lakh each on the Managing Director as well as Chief Financial Officer under Section 78A of the Finance Act, 1944 - These officers have merely complied with the agreement entered into between the parties and no knowledge can be imputed on them that they have deliberately violated the provisions of the Act. - The imposition of penalty on the appellants is not justified - AT
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