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2001 (1) TMI 6 - ALLAHABAD HIGH COURTExtract: ....... section 142 of the Act, he is not liable for penalty. Considering the facts and circumstances of the case we are of the opinion that a substantial question of law arises. We direct the Income-tax Appellate Tribunal, Allahabad, to draw up statement of facts in the present case and refer the question of law as framed above for opinion of this court.
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