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Procedure.

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..... ub-section (1) shall be issued- (a) during the pendency of any proceedings under this Act for the relevant previous year, in respect of penalty referred to in section 41; (b) within a period of three years from the end of the financial year in which the default is committed, in respect of penalties referred to in section 45. (3) No order imposing a penalty under this Chapter shall be made .....

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..... rity shall issue a notice within the stipulated time period to any assessee requiring him to show cause why the penalty should not be imposed on him. It further provides that no order imposing a penalty shall be made under Chapter IV unless the assessee has been given an opportunity of being heard. The said clause also lays down the procedure for approval of an order by the Joint Commissioner. - .....

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