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ii. The principle laid down by this Court, in our view, has been correctly followed by the Revenue and we find no illegality in the department initiating penalty proceedings in the instant case. We, therefore, fully agree with the view of the High Court. Hence, the appeal lacks merit and is dismissed. There shall be no order as to costs.

13. The Ld. AR submitted before us that because of mistake, the assessee had raised the claims and the said mistake was a human error which has crept into while making the computation.