High Court Upholds 25% Penalty Restriction u/s 140A(3), Supported by Tribunal and Section 221 Provisions.

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....Restriction of penalty imposed u/s 140A(3) to 25% - when the authorities were justified in restricting the penalty to 25% based on cogent material and finding, more so when it is discretionary as the same is clearly rendered u/s 221 order of tribunal sustained - HC....