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1994 (1) TMI 133 - ITAT NAGPUR
Extract:
.......and confirmed by the CIT(Appeals) by relying upon the Explanation to section 271(1)(c). 7. After taking into consideration all the facts and circumstances of the case, we are of the opinion that the CIT(Appeals) was not justified in confirming the penalty imposed by the Assessing Officer. We delete the same. 8. In the result, the appeal is allowed.