2007 (12) TMI 161

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....er section 76, 77 and 78 of the Finance Act, 1994 by revision order dated 28-11-2006. After hearing both the sides and on perusal of the records, I find that the Commissioner while imposing penalty have observed that the appellants had not adduced any reasonable cause for such failure to pay the tax before the adjudicating authority or before him and therefore, benefit of Section 80 cannot be gran....