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1987 (1) TMI 18 - HC - Income TaxExtract: ....... the element of wilfulness is relevant. Section 36(3) speaks of this element and only because the rate is computed on interest basis, it cannot be said that the penalty imposed is in effect interest an allowable deduction. Hence, we answer the question referred in the negative and against the assessee. The assessee to bear the costs of the Revenue.
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