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2007 (1) TMI 529 - ALLAHABAD HIGH COURTExtract: .......ver. It is settled principle of law that the proceeding under section 21 of the Act cannot be initiated and the tax under section 21 of the Act cannot be levied merely on account of change of opinion. Thus, I do not find any error in the order of the Tribunal and is, accordingly, upheld. In the result, revision fails and is, accordingly, dismissed.
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