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1991 (3) TMI 195 - ITAT DELHIExtract: ....... been no application of any mind and that, the assessee has the right to challenge the levy. Since the interests were levied without application of any mind, it is only proper that the assessing officer may allow an opportunity, for which this issue is set aside to the file of the assessing officer. 9. In the result, the appeals are allowed in part
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