Penalty Imposed Under Finance Act Section 78 for Fact Suppression; No Relief Sought u/s 80.

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....Levy of penalty u/s 78 - suppression of facts - the appellant has not sought the benefit of section 80 of the Finance Act, 1994 in this appeal. - payment of service tax prior to issue of show-cause notice is no ground to oppose the section 78 penalty - AT....