Penalties under Finance Act, 1994 Sections 77 & 78 questioned; 2010 amendment may offer immunity due to quasi-criminal nature.

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....Imposition of penalty under Section 77 & 78 of Finance Act, 1994 - When there was amendment of the law to grant immunity from persecution in terms of the Finance Act, 2010, the penalty proceeding being quasi-criminal in nature, so the appellant also deserves consideration for exoneration from levy of penalty. - AT....