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1995 (9) TMI 327 - MADRAS HIGH COURTExtract: .......e on the part of the assessee. Hence, penalty under section 12(3) is also not possible. Therefore, the decision in Devendran and Co. s case 1983 53 STC 229 (Mad.) is not applicable to the present case. We are not able to interfere with the order of the Tribunal for that reason. In the result, the revision is dismissed. No costs. Petition dismissed.
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