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1993 (11) TMI 6 - HC - Income TaxExtract: .......n questions Nos. 2 and 3 referred to us is without any factual basis. No penalty could be imposed on the assessee merely on the basis of the abovereferred offer of settlement, i.e., letter dated March 5, 1986, read with the letter dated December 7, 1982. The application made by the Revenue herein fails. The rule is discharged. No order as to costs.
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