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1987 (4) TMI 96 - ITAT BOMBAY-AExtract: .......ion to be exercised judicially and on a consideration of all the relevant circumstances. Viewed in this context, we have no hesitation in holding that this is not a fit case for imposition of penalty under s. 273(2)(a). The penalty under s. 273(2)(a) imposed by the ITO was, therefore, not Justified and is hereby cancelled. 6. The appeal is allowed.
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