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1980 (9) TMI 9 - HC - Income TaxExtract: .......inion, therefore, on the facts and in the circumstances of the case, the Tribunal was not justified in holding that penalty was exigible. For all these reasons, our answer to the questions referred to this court are in the negative and in favour of the assessee. In the circumstances of the case, parties shall bear their own costs of this reference.
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