2007 (3) TMI 762

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....lised for wilful breach of law and lawlessness shall not be allowed to perpetuate. He submitted that entire order of adjudication should have been confirmed by the Ld. Appellate Authority without any lenient consideration when the respondent submitted nil return suppressing facts and even after clarification was issued to remove confusion. They filed revised return for October, 1998 to March, 1999....

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....vice tax from the clients, they faced serious financial hardship for which there was unintentional delay. They voluntarily came forward to comply with the law and gradually also discharged their tax liability. When they could understand that the levy is justified, they carried out the direction of the Ld. Commissioner (Appeals) and already discharged the penalty demand of ₹ 1,43,052.40. This....

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....be fair, acknowledging liability, filing revised return for part of the period October, 1998 to March, 1999. But remained silent for rest of the period. Record does not reveal that mischief like fraud, collusion, wilful mis-statement or suppression of fact or deliberate breach of law which are elements of section 78, were not present in this case. It appears there were reasonable cause on the part....