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The High Court of Allahabad ruled that the Income-tax Appellate Tribunal's penalty orders were not within the jurisdiction of the Income-tax Officer (ITO) due to an amendment to section 274(2) of the Income-tax Act. The court held that only the ITO had the authority to impose penalties up to Rs. 25,000. The penalty orders issued by the Income-tax Appellate Tribunal were deemed invalid.
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