Appellant Challenges Penalty u/s 271C, Citing Vivad se Vishwas Scheme Settlement of Section 201(1) Proceedings.

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....Levy of penalty u/s 271C - Whether appellant is entitled to immunity from penalty as the appellant has opted for VSVS in respect of order u/s 201(1)? - Since the dispute is related to the quantum of 201(1) proceedings the same is already settled and therefore, penalty cannot be imposed subsequently under Section 271C of the Act. - AT....