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1983 (1) TMI 24 - HC - Income TaxExtract: .......)(c). The justification for actual imposition of penalty must be found under s. 271(1)(iii) of the Act which we have held does not apply to the present case as our answers to the two other questions would establish. Since the assessee has substantially succeeded in this reference, the Department will pay the assessee s costs. Counsel s fee Rs. 500.
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