Tribunal Mistakenly Bypassed Reasonable Cause Requirement u/s 78 When Extended Limitation Invoked u/s 73(1) Proviso.

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....Waiver of penalty u/s 80 - Tribunal was in error holding that there would be no occasion to establish a reasonable cause within the meaning of section 78, once, the extended period of limitation had been validly invoked under the proviso to section 73(1) - HC....