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1998 (8) TMI 109 - ITAT AHMEDABAD-CExtract: ....... have also been taxed in the hands of the recipients in the asst. yr. 1986-87 on substantive basis. In that view of the matter, in our opinion, the addition cannot be sustained. 4. The ground regarding interest under s. 215 of the Act is consequential in nature. The remaining grounds are not pressed by the assessee. 5. The appeal is partly allowed.
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