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2001 (2) TMI 118 - DELHI HIGH COURTExtract: .......o rehear the appeal only after taking into account the date of reference to the Inspecting Assistant Commissioner. If the reference was prior to April 1, 1976, the decision in Sharadammma s case 1996 219 ITR 671(SC) would apply. If the reference is after April 1, 1976, imposition of penalty would be illegal. We dispose of the reference accordingly.
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