TMI Blog2009 (3) TMI 119X X X X Extracts X X X X X X X X Extracts X X X X ..... bunal held that this itself means that the Revenue is of the view that the applicant was ignorant about his tax liabilities. If that be so, the provisions of Section 80 would come into play – penalty set aside - ST/170/2008 - A/721/WZB/Ahd/2009-CII - Dated:- 27-3-2009 - Smt. Archana Wadhwa, Member (Judicial) (Final Order No. A/721/WZB/Ahd/2009-CII and Stay Order No. S/543/WZB/Ahd/2009-CII ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accordingly. 3. However, it is only in the year 2007 that the appellant approached the Revenue for registration and submitted that they were not aware of their tax liabilities and it is only on the legal advice given to them recently, that they have now approached the Revenue for registration of their service. They also offered to pay the duty for the past period and in fact paid the duty of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... He accordingly, justifies imposition of penalty upon the appellant. 6. On going through the orders I find that the only reason for invocation of Section 78 by Commissioner (Appeals) is that ignorance of law is no excuse. This itself means that the Revenue is of the view that the applicant was ignorant about his tax liabilities. If that be so, the provisions of Section 80 would come into play. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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