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1986 (10) TMI 80 - ITAT DELHI-BExtract: .......e the assessee had failed to furnish any reply to the show-cause notice issued by the Commissioner prior to the passing of the impugned order under section 263, I would agree with the conclusion arrived at by the learned Judicial Member in the special facts and circumstances of the case. 2. The appeals by the assessee fail and are hereby dismissed.
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