Whosoever contravenes or fails to comply with, any of the provisions of this Act or the rules made thereunder or any order or direction made or given under this Act or the rules thereunder, the Commissioner shall, if no other penalty is provided under this Act for such contravention or failure, impose on him a penalty of an amount not exceeding twice the amount of tax involved or tax evaded or sought to be evaded where it is practicable to quantify such amount or an amount not exceeding fifty thousand rupees in any other case, subject to a minimum of two thousand rupees and where such contravention or failure is a continuing one, a further penalty of one hundred rupees for every day during the period of continuance of the contravention or failure:

Provided that no penalty under this section shall be imposed unless the person concerned is given a reasonable opportunity of being heard.