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1989 (3) TMI 112 - PUNJAB AND HARYANA HIGH COURTExtract: ....... CIT 1988 172 ITR 250. Accordingly, we hold that the Tribunal was in error in placing the onus on the Department instead of raising the legal presumptions against the assessee, which he failed to rebut, and in cancelling the penalty. In view of the above, the question is answered in favour of the Revenue, in the negative, with no order as to costs.
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