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1991 (3) TMI 111 - BOMBAY HIGH COURTExtract: .......ed counsel for the assessees. In our judgment, that decision has no bearing on the question before us. Accordingly, we are in agreement with the Tribunal in holding that the provisions of section 164(1) of the Act are applicable in this case. The question is, therefore, answered in the affirmative and in favour of the Revenue. No order as to costs.
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