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2003 (7) TMI 373 - CESTAT, MUMBAIExtract: .......l action taken against the appellants. 6. emsp We have carefully considered the rival submissions. The contention of the appellants is tenable having regard to the language of Rule 96ZQ and the Tribunal rsquo s order cited supra. We, therefore hold that the penalty imposed is not sustainable and accordingly, set aside the same and allow the appeal.
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