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Penalty Upheld u/s 78; No Reinstatement u/s 76 Despite Appeal Error in Penalty Reduction Decision.

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....Inasmuch as a penalty under Section 78 is being sustained, there is no justification for restoring the penalty under Section 76 as sought for by the department. However, the Commissioner (Appeals) has clearly erred in reducing the penalty imposed by the original authority under Section 78 without any valid reasons..... - AT....

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Penalty Upheld u/s 78; No Reinstatement u/s 76 Despite Appeal Error in Penalty Reduction Decision.