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The High Court of Patna held that penalty under section 271(1) can be imposed even after charging interest under section 139 for delayed submission of return. The Appellate Tribunal was not correct in holding otherwise. The judgment was in favor of the Revenue and against the assessee for the assessment year 1973-74. No costs were awarded. The judgment will be sent to the Income-tax Appellate Tribunal in Patna.
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