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2010 (4) TMI 1233 - AT - Income TaxExtract: .......cerned, the assessee having not been able to discharge the burden that lay upon it by Explanation 1 to s. 271(1)(c) of the Act. Thus, ground no.1 in the appeal is dismissed.. 22. No additional ground having been raised in terms of the residuary ground, this ground is ,accordingly, dismissed. 23. In the result, both these appeals are partly allowed.
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