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2005 (6) TMI 486 - ITAT MUMBAI
Extract:
.......d. 23. Ground No. 11 requires no interference as the penalty proceedings are independently initiated and adjudicated. They are to be decided as per facts and law related to them. Hence this ground is rejected. Ground No. 12 is general and hence, it is also rejected. 24. In the result, the appeal of the assessee is partly allowed as indicated above.