Compounding Fee Under Income Tax Act: 100% of Tax Attempted to Be Evaded Per Section 279 and 276C(1) Guidelines.

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....Determination of compounding fee u/s 279 - When the CBDT circular refers to the amount sought to be evaded, it must be seen and understood in light of the provisions contained in section 276C(1) and in turn must be seen as amount sought to be evaded. 100% of tax sought to be evaded would be the basic compounding fees.....