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2002 (2) TMI 907 - ITAT KOLKATAExtract: .......year 1985-86. Therefore, it can be safely presumed that when the assessee was allowed relief for the immediately preceding year by the Tribunal, it could not apprehend that the claim of loss would be disallowed. 6.2 In such circumstances, I am of the view that both the penalties are liable to be cancelled. 7. In the result, the appeals are allowed.
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