2014 (11) TMI 106

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....ajpayee for the Appellant Mr. Sanjiv Shah for the Respondent JUDGEMENT 1] We have heard Mr. Vimal Gupta, learned Senior Counsel, appearing for the Revenue in support of this Appeal. We have heard Mr. Shah, learned counsel, appearing for the Respondent. 2] With their assistance, we have gone through the concurrent findings on the point of deletion of penalty. In para 5.2 of the order of....

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.... approached the Settlement Commission during some assessment years and accepted the order of the Settlement Commission. However, in the present assessment year, it raises the very claim and, therefore, the Commissioner's findings could not have been endorsed by the Tribunal and this is a substantial question of law particularly when it failed to assign independent reasons of its own. 4] We ....