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1982 (8) TMI 38 - GAUHATI HIGH COURTExtract: .......force it . In our opinion the provision for penalty is a substantive provision and the authority to levy penalty is only procedural. For the reasons stated above and in the premises, the question referred to this court is answered in the affirmative and in favour of the Department. Each party will pay and bear their own costs. T. C. DAS J.-I agree.
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