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2001 (11) TMI 56 - HC - Income TaxExtract: .......that non-initiation of penalty proceedings under section 271(1)(c) do not render the assessment made dated January 16, 1989, erroneous or prejudicial to the interests of the Revenue and consequently the Commissioner of Income-tax is not justified in assuming under section 263, is therefore answered in favour of the assessee and against the Revenue.
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