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1976 (2) TMI 7 - HC - Income TaxExtract: ....... the latter provision, the requirements of section 22(2A) would stand satisfied. It is clear enough that their Lordships did not hold that penalty proceedings under s. 271 cannot be initiated. Accordingly, we answer the question referred to us in the affirmative. The question is answered against the assessee. The parties shall bear their own costs.
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