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1997 (8) TMI 71 - HC - Income TaxExtract: ....... case, the abovesaid Explanation would be applicable to the penalty proceedings, which though initiated after the date of enactment of the Explanation arose out of the return filed prior to that date? The Tribunal shall draw up a statement of the facts of the case and refer the abovesaid questions for the opinion of the court. No order as to costs.
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