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1984 (4) TMI 2 - HC - Income TaxExtract: .......at since the penalty imposed was based on the earlier assessment order, the second proceeding also must be decided in favour of the assessee. Mr. Sharan, appearing on behalf of the petitioner, fairly conceded that he cannot now urge otherwise. For the reasons mentioned above, the question is decided in the affirmative, i.e., against the Department.
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