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1982 (4) TMI 8 - HC - Income TaxExtract: .......d then seen whether, in the circumstances of the case, the assessee had proved that there was no gross or wilful neglect on his part. (2) The Tribunal was not justified in cancelling the penalty. The Tribunal will have to re-examine that question by invoking the Explanation to section 271(1)(c). There will be no order as to costs of this reference.
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