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1981 (11) TMI 86 - ITAT DELHI-AExtract: .......h circumstances, the assessee has to place only a probable case to prove that she was nto guilty of fraud or gross or wilful neglect. We, therefore, hold that the penalties levied by the WTO cannot be sustained. We, therefore, cancel the penalty orders of the WTO in both the assessment years. 10. In the result, both the appeals are allowed in full.
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