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2003 (3) TMI 301 - ITAT RAJKOTExtract: .......prejudice to the revenue. So far as non-initiation of penalty proceedings is concerned, we uphold the contention of the ld. counsel that that cannot be the ground for invoking jurisdiction under section 263 of the Act. However, in substance, the orders of the CIT are upheld. 17. In the result, the three appeals of the three assessees are dismissed.
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