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1985 (8) TMI 35 - HC - Income TaxExtract: .......nswer to question No. 2 has to be that, on the facts and circumstances of this case, the Tribunal was not right in holding that no penalty was exigible. For the reasons recorded above, we answer both the questions referred to us in favour of the Department and against the assessee, i.e., in the negative. However, there will be no order as to costs.
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