High Court Rules Penal Interest and Penalty Recovery Unsustainable; Sections 114A and 28AB Not Applicable in Show Cause Notice Case.

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....Demand of Interest - Department is unable to deny that neither Section 114A nor Section 28AB could have been invoked as far as the SCN issued to the Petitioner was concerned. Therefore, in the interests of justice recovery of penal interest u/s 28AB as well as the penalty u/s 114A by the department is not sustainable - HC....