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of Penalty levied u/s 221 - default on the part of assessee or deeming the assessee to be an assessee on default - Failure to collect tax u/s 206C while selling timber - Since matter is already being send back to the file of the AO for considering the declaration Form no. 27C, the penalty levied for default in making payment u/s 221of the Act cannot be sustained on the principle that when the foundation goes, the super-structure falls - AT
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