Penalty Imposed u/s 78 Overturned for Exceeding Section 76 Limit; 25% Reduction Option Wasn't Offered.

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....Waiver of penalty is pleaded as the penalty under Section 78 ibid has been imposed and for an option to pay 25% (reduced) mandatory penalty under Section 78 ibid as the option was not given at the lower levels. - Levey of penatly in excess of penalty u/s 76 set aside- AT....