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1984 (2) TMI 221 - ITAT PUNEExtract: .......s agreeing for the revision of assessment. The assessee rsquo s agreeing in that case was certain, again in this case the assessee agitated the said ground before the ITO at the time of passing the assessment order itself. Therefore both these authorities are on different footing. 15. In the result, the Department fails and the appeal is dismissed.
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