Commissioner Cannot Solely Rely on Initial Grounds to Reduce or Waive Penalties u/s 273A of the Income Tax Act.

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....Power to reduce or waive penalty under section 273A - if the Commissioner while exercising power under Section 273-A of the Act places sole reliance upon grounds that led to imposition of penalty and interest, such an exercise of power, would in essence, be contrary to power conferred by Section 273-A - HC....