2024 (9) TMI 1690

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....ARMA, J (ORAL) Learned counsel for the petitioners has submitted that the order passed by the Supreme Court in Civil Appeal Nos. 63-66 of 2022, allowed the petitioners to make a representation to the authority for waiving the penalty, which application can be considered by the appropriate authority on its own merits. Learned counsel for the petitioners further submits that the representation wa....

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....Thereafter, it seems that the petitioners company submitted a letter on 28.03.2022 requesting for conversion of outstanding liability into monthly instalments, which was allowed by the concerned Assistant Commissioner. The issue, therefore, stood closed at that level itself with regard to the aspect regarding waiver of penalty. A presumption has to be drawn in terms of the aforesaid communication....