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2000 (3) TMI 22 - KERALA HIGH COURTExtract: ....... 165 ITR 14 (SC)). Since the Tribunal has based its conclusion on factual aspects keeping the correct principles in mind and held that the proviso to clause (B) of Explanation 1 to section 271(1)(c) applies, no question of law arises. Our answer to both the questions referred is in the affirmative, in favour of the assessee and against the Revenue.
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