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of Levy of penalty of IEC code holder and middleman - Allowing third party to use its IEC code - Bonafide Belief - Misdeclaration of imported goods by third party - There is no active role played by these appellants save and except facilitating the use of IEC code by another for some monetary consideration - the penalty of Rs. 12 lakhs u/s 112(a) is reduced to Rs.50,000/- - AT
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