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1991 (4) TMI 16 - HC - Income TaxExtract: .......ovision is capable of two alternative meanings, the one favouring the taxpayer is to be adopted, particularly when such a provision purports to impose penal interest. For the reasons aforesaid, we answer the question in this reference in the affirmative and in favour of the assessee. There will be no order as to costs. SHYAMAL KUMAR SEN J.-I agree.
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