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1991 (1) TMI 92 - ALLAHABAD HIGH COURTExtract: .......at the relevant time does not come to the rescue of the Revenue, for herein the several reasons given by the Inspecting Assistant Commissioner for imposing penalty have been clearly dealt with and negatived by the Tribunal. Accordingly, the question referred is answered in the affirmative, that is, in favour of the assessee and against the Revenue.
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