Section 78 Penalty Contested: Revenue-Neutral Situation Leads to No Malafide Intent, No Penalty Imposed on Assessee.

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....Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.....