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1996 (5) TMI 259 - CEGAT, MADRASExtract: .......r affording the opportunity of hearing to the assessee before approval of the same. We observe that there was no warrant in the facts and circumstances of the case for levy of any penalty on the appellants. We therefore set aside the order of the learned lower authority so far as levy of penalty is concerned and allow the appeal in the above terms.
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