his provision thus while prescribing punishment for wilful attempt to evade tax, penalty or interest chargeable, provides for a more severe punishment in case the amount sought to be evaded exceeds Rs. 2,50,000. For the rest, punishment prescribed is lesser. This prescription of punishments in two categories is thus linked with the amount sought to be evaded. This amount sought to be evaded is in relation with the action of a person of a wilful attempt to evade tax, penalty or interest chargeable. In the prescription of punishment thus, when there is a reference to amount sought to be evaded, it must be seen in light of the wilful attempt on the part of the concerned person to evade tax, penalty or interest. This provision thus, links the severity of punishment on the amount sought to be evaded and thus, in turn has relation to the attempt at evasion of tax, penalty or interest. Thus, when the CBDT circular refers to the amount sought to be evaded, it must be seen and understood in light of the provisions contained in s. 276C(1) and in turn must be seen as amount sought to be evaded. 100 per cent of tax sought to be evaded would be the basic compounding fees which in the present case would be Rs. 2,71,000 and not Rs. 8,70,000 as computed by the Departmental authorities. The rest of the computation is consequential and automatic. The impugned communication dt. 20th March, 2018 is therefore, set aside. The respondent shall carry out fresh computation of the petitioner’s liability to pay compounding charges in terms of this order. We are informed that, to avoid any complication, the petitioner has under protest, paid up the entire amount of Rs. 10,49,000 as demanded by the Department. Once such fresh computation is made, the excess would be refunded by the Department to the petitioner latest by 31st Oct., 2018.