Appellant Denied Reduced Penalty u/s 78 for Not Depositing 25% of Penalty Before Deadline.

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....Benefit of reduced penalty u/s 78 - the appellant had failed to deposit 25% of the imposed penalty before the issuance of show cause notice or within 30 days of finalization of demand by the adjudicating authority - appellant could not be granted option to pay 25% (reduced) mandatory penalty under Section 78 of the Act.....