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2007 (3) TMI 218 - ALLAHABAD HIGH COURTExtract: ....... as such the order of the Tribunal deleting the penalty cannot be sustained. We, accordingly, answer the question referred to above in the negative that is in favour of the Revenue and against the assessee with further direction to decide the matter afresh after considering Explanation 1 to section 271(1)(c) inserted with effect from April 1, 1976.
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