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1986 (1) TMI 19 - HC - Income TaxExtract: .......at the assessee, in this case, will have to prove that there was no fraud or gross or wilful neglect on his part, and that the concerned Income-tax Authority will have to look into the totality of the facts and circumstances and decide the question whether the assessee has been able to prove lack of fraud or any gross or wilful neglect on his part.
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