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2001 (12) TMI 530 - AT - Income TaxExtract: ....... Co., affirmed by the Apex Court, has been followed. I would, therefore, accept the assessee rsquo s contention that on the facts and in the circumstances of the case, penalty under section 271(1)(c) was not exigible in law for the two assessment years under consideration. The penalty orders are cancelled. 6. In the result, the appeals are allowed.
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