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1953 (4) TMI 25 - ALLAHABAD HIGH COURTExtract: .......annot operate as res judicata in proceeding for imposition of penalty where entirely different facts have to be found. The second question must, therefore, be answered in the negative. Since we are answering one question in favour of the assessee and the other in favour of the Department we make no order as to costs. Reference answered accordingly.
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