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2002 (7) TMI 404 - ITAT DELHIExtract: .......n rsquo ble Gujarat High Court and cancel the penalty. This would mean that vis-a-vis the Revenue rsquo s appeal, we uphold the order of the Commissioner of Income-tax (Appeals) on a ground different to the one on which he had allowed partial relief. 12. In the result, the assessee rsquo s appeal is allowed whereas that of the Revenue is dismissed.
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