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1972 (3) TMI 26 - CALCUTTA HIGH COURTExtract: .......sment already made, the question as to under which Act, viz., the Indian Income-tax Act, 1922, or the Income-tax Act, 1961, penalty would be recovered, would have to be considered. It seems to us that a discussion on this question at this stage is premature. For these reasons, I agree with the order made by my Lord. Appeal is, therefore, dismissed.
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