Appellant receives 25% penalty reduction due to excess deposit exceeding confirmed duty demand, interest, and penalty.

Entitlement to reduced penalty - total amount deposited at the time of investigation is much more than the confirmed duty demand, interest thereon and 25% penalty - there is no reason to deny the benefit of a reduced penalty of 25% to the appellant even though the appellant had not opted but the fact remains that the amount remains very much with the department - AT .....

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