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11,02,225.00. By order dated nil September, 2002, the Deputy Commissioner of Income Tax levied a penalty of Rs. 31,71,692.00. He distinguished the decision of the Punjab http://JUDIS.NIC.IN SUPREME COURT OF INDIA Page 4 of 17 and Haryana High Court in Prithipal Singh’s case (supra), which was affirmed by this Court on the ground that