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2009 (6) TMI 684 - AT - Income TaxExtract: .......SOT 254 lays down the requirements for levy of penalty under section 271(1)(c), we uphold that the assessee is entitled to immunity under Explanation 5(2) to section 271(1)(c). We allow the assessee rsquo s appeal and delete the penalty of Rs. 16,83,000 levied by the Assessing Officer. 14. In the result, the appeal filed by the assessee is allowed.
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