Assessee Misses Deadline for Reduced Penalty Payments u/s 78, Court Approval Doesn't Waive Liability.

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....Benefit of reduced penalty - reduced penalty amounts were not deposited by the assessee u/s 78 within stipulated time, which is a statutory mandate. No doubt they were paid in the interregnum, at a later stage, pursuant to the permission granted by this Court, however, that did not in any manner mitigate the appellant’s liability....