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1992 (9) TMI 53 - ALLAHABAD HIGH COURTExtract: ....... a contrary view and in imposing penalty on the assessee on the basis of such an erroneous view. In our opinion, the assessee had discharged its burden under the Explanation to section 271(1) of the Act on the basis of the materials on record and no penalty could be legally imposed upon him under that section. The reference is answered accordingly.
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