https://www.taxtmi.com/caselaws?id=55166 The Tribunal rejected the assessee's appeal, ruling that by seeking waiver of penalty, the assessee admitted liability, thereby forfeiting the right to appeal. The decision emphasized that seeking waiver implied seeking mercy and pardon, making it inconsistent to deny liability in an appeal. The Tribunal aligned with the Gujarat High Court's view, distinguishing between challenging a penalty in an appeal and seeking waiver under a specific provision. Consequently, the Tribunal did not assess the appeal's merits, as the admission of liability through the waiver application rendered the appeal untenable. en-us Tue, 27 Sep 1983 00:00:00 +0530 Sun, 06 Feb 2011 03:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55166 The Tribunal rejected the assessee's appeal, ruling that by seeking waiver of penalty, the assessee admitted liability, thereby forfeiting the right to appeal. The decision emphasized that seeking waiver implied seeking mercy and pardon, making it inconsistent to deny liability in an appeal. The Tribunal aligned with the Gujarat High Court's view, distinguishing between challenging a penalty in an appeal and seeking waiver under a specific provision. Consequently, the Tribunal did not assess the appeal's merits, as the admission of liability through the waiver application rendered the appeal untenable. Case-Laws Wealth-tax Tue, 27 Sep 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55166