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1985 (10) TMI 43 - PUNJAB AND HARYANA HIGH COURT
Extract:
.......uld not reject this contention on the ground that the Explanation to section 271(1)(c) was not taken support of by the Income-tax Officer and was not pleaded before the Appellate Assistant Commissioner. Consequently, we answer the question in the negative, i.e., in favour of the Revenue and against the assessee. There shall be no order as to costs.