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2012 (4) TMI 595 - AT - Income TaxExtract: .......he decision cited by the ld. DR would be distinguishable on the facts of the case because in that case, requisite satisfaction had been recorded by the AO. In the result, we do not find any merit in the departmental appeal. The same is accordingly dismissed. 8. In the result, the departmental appeal is dismissed. Order pronounced in the open court.
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