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2011 (11) TMI 699 - GUJARAT HIGH COURTExtract: .......orating previsions of Section 215, 216 or 217 into penalty proceedings under Section 221 would not be ordinarily justified. However, we are of the view that order of Tribunal is one quantifying the penalty relating to length of default. In thus discretionary exercise of powers by Tribunal, we see no question of law arising. Tax Appeal is dismissed.
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