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1986 (10) TMI 61 - ITAT ALLAHABAD-BExtract: .......e on him by virtue of section 19(2) read with section 21 of the Act. We, therefore, find no illegality or irregularity in the order of the Commissioner (Appeals) in setting aside the assessment and directing the WTO to make a fresh assessment, after invoking the provisions of section 19. 7. The appeal, therefore, fails and is accordingly dismissed.
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