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1984 (5) TMI 31 - HC - Income TaxExtract: .......t the Department and hold that, on the facts and in the circumstances of the case, it was permissible for the assessee to raise the question of penal interest under s. 217 of the Act before the Appellate Tribunal. Since the answers have been equally divided, I shall make no order as to costs. NAZIR AHMAD J.-I agree. PRABHA SANKER MISHRA J.-I agree.
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