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1997 (5) TMI 429 - AT - Income TaxExtract: .......that the issue was not pressed before him. As the assessee has not refuted the finding of the Commissioner (Appeals) either in his pleadings or by way of evidence, we are of the opinion that this ground do not arise out of the order of the Commissioner (Appeals) and consequently the same is rejected. 11. In the result, the appeal is partly allowed.
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