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    <title>2023 (12) TMI 304 - CESTAT CHANDIGARH</title>
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    <description>Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, penalty relief could not be denied to co-noticees merely because they did not file separate declarations where they were otherwise eligible and the liability related only to penalty or late fee; the omission was treated as procedural, and the benefit was allowed. Penalty under Rule 26 of the Central Excise Rules, 2002 was also unsustainable because the record did not show positive connivance or culpable participation, the findings were inconsistent with the order itself, and the penalty had been imposed by reference to provisions not in force during the material period; the penalties were set aside.</description>
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