Tribunal Rules No Penalty Reduction u/s 78 Without Initial Applicability; No Discretion on Non-Imposed Penalties.

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....Reduction in the quantum of penalty imposed u/s 78 - Unless the penalty under Section 78 of the Act itself is leviable on the Assessee, there is no question of any reduction of the quantum of penalty to 25% thereof by the learned Tribunal in its discretion. What is not at all leviable, cannot be reduced.....