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1992 (7) TMI 102 - ITAT AHMEDABAD-BExtract: .......y of penalty under the terms of cl. (a) or cl. (b) of s. 271(1)(i). As shown earlier there is not even a positive figure of rupee one for these two years so as to attract the penal provisions under cl. (a) as was done by the ITO. Even from this angle penalties imposed by the ITO are not warranted in law. 15. In the result the appeals are dismissed.
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