Bar of limitation for imposing penalty

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..... dropping the proceedings for imposing, the penalty under this Chapter may be revised, or revived, as the case may be, on the basis of assessment of the tax base, as revised after giving effect to the order of Commissioner (Appeals), Appellate Tribunal, the National Tax Tribunal or the Supreme Court or order of revision under section 194. (3) An order revising the penalty under sub-section (2) .....

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