Section 22. Appeal against penalty.

22. Any assessee objecting to the amount of penalty imposed upon him under section 21 or denying any liability for such penalty may, within 30 days of the date of receipt of the notice of demand under the said section, appeal to the Commissioner and the provisions of sub-sections (2) to (4) of section 11 shall thereupon mutatis mutandis apply: Provided that where on an appeal under section 11 or on an application for revision under section 12 the assessment made under section 8 has been set aside or the amount of holding tax has been reduced, the penalty imposed under section 21 shall be deemed to have been written off or reduced proportionately, as the case may be.