penalty under service tax


Dear Sir,

Sir, based on the formal notice from the service tax department, the entire service  tax and interest was paid before issue of the SCN for the period from 2013-2014 to June 2017. However, the A.O, passed the order-in-original for levying the penalty under the second proviso to section 78(1) of the finance Act, 1994, ie. levying  reduced penalty 25%for which I would like to go for appeals for preferring the penalty @ 15% as against 25%. But I heard that the above supra mentioned section inherent meaning is that within 30days from the receipt of the order-in- original, so demanded/reduced penalty has to be paid, otherwise, the option of reduced penalty @ 25% not eligible, and again it gets fit for 100% penalty is it right?


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