Appellant Assessee Wrongly Denied Benefit u/s 73(3); No Penalty Imposed Due to Revenue's Misinterpretation.

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....Levy of penalty - the whole case is due to interpretational issue (change of opinion) on the part of the Revenue - it is further found in the facts and circumstances of this case, that the benefit of closure under section 73(3) has been wrongly denied to the appellant assessee, and no show-cause notice was required to be issued. - No penalty - AT....