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1983 (6) TMI 49 - ITAT BOMBAY-AExtract: .......rt, a separate order u/s 217 could be passed at any time. As the order is expressly passed as one u/s 154, we do not find our way to treat the same as an order u/s 217. 8. In view of the finding above, we do not go into the question whether the circumstances of the case justify the imposition of the penalty. 9. In the result, the appeal is allowed.
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