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1992 (9) TMI 131 - ITAT DELHI-EExtract: .......any penalty for the late filing of a return by an educational institution, and which the assessee has been held to be by the Tribunal. In this view of the matter, we, in the ultimate analysis, opine that the provisions of section 271(1)(a) are not at all attracted. The order of the DC (Appeals) is, accordingly, confirmed. 9. The appeal is dismissed
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