Petitioner Challenges Penalties u/s 70(2) as Covered by Karasamadhana Scheme 2021; Respondents' Argument Deemed Erroneous.

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....Seeking waiver of penalty as provided under the Karasamadhana Scheme, 2021 - The contention urged by the respondents that waiver of penalty levied upon the petitioner under Section 70(2) in the reassessment orders dated 24.09.2020 and 27.04.2021 do not come within the scope and ambit of the scheme since Section 70(2) does not find a place in Clause No.3 of the scheme is concerned, the said contention is clearly erroneous in as much as the said penalty is undisputedly in relation to reassessment proceedings, which were completed on 24.09.2020 and 27.04.2021 much prior to the cut off date dated 21.07.2021 as contemplated in Clause 2 of the Scheme - HC....