Section 73(3) Waiver Denied: Section 73(4) Conditions Prevail Over Section 78 Penalty Waiver Claim.

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....Penalty u/s 78 of FA - waiver of penalty - The appellants contention that section 73(3) is applicable in their case is not correct - Once, the ingredients of section 73(4) are present the provisions of section 73(3) are not applicable - AT....