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2005 (11) TMI 529 - AT - Income TaxExtract: .......ound pertains to penalty proceedings under section 271(1)(c) of the Act. After considering the submissions, the same does not arise out of the order of the learned CIT (Appeals). 12. The last ground is merely prayer and requires no deliberation. In the result, appeal of the assessee is dismissed and the stand of the learned CIT (Appeals) is upheld.
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