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1997 (7) TMI 192 - ITAT DELHI-CExtract: .......discharged and, therefore, penalty under section 221 is exigible. On the totality of facts and circumstances, therefore, we find that penalty under section 221 cannot be upheld. It is cancelled. 10.1 Since interest under section 201(1A) is on the same ground as the levy of penalty, levy of interest is also quashed. 11. Both the appeals are allowed.
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