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    <title>2016 (1) TMI 347 - GUJARAT HIGH COURT</title>
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    <description>Penalty was held not leviable where the assessee paid tax and interest after a bona fide belief that the amount was not taxable. Section 80 of the Finance Act, 1994 barred penalty because the taxability issue was debatable, and the later insertion of Explanation 3 to section 67, expressed as being for removal of doubts, supported the view that the position was not free from ambiguity. The assessee&#039;s prompt payment of tax and interest further established reasonable cause, so deletion of penalty was justified.</description>
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      <description>Penalty was held not leviable where the assessee paid tax and interest after a bona fide belief that the amount was not taxable. Section 80 of the Finance Act, 1994 barred penalty because the taxability issue was debatable, and the later insertion of Explanation 3 to section 67, expressed as being for removal of doubts, supported the view that the position was not free from ambiguity. The assessee&#039;s prompt payment of tax and interest further established reasonable cause, so deletion of penalty was justified.</description>
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