Penalty under Finance Act Section 78 waived due to bona fide belief; no fact suppression found in audits.

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....Imposition of penalty - Section 78 of the Finance Act, 1994 - the non-payment of tax was on account of bonafide belief and the Revenue had conducted Audits which would go to show that there was in fact no suppression of facts - penalty was rightly waived u/s 80 - AT....