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2004 (7) TMI 272 - AT - Income TaxExtract: .......r s. 271E for payment of loan which was not an offence in asst. yr. 1999-2000. The amendment was not procedural. Moreover, without prejudice to the above, we are of the view that penal provisions are never retrospective. Accordingly, the penalty under s. 271E is directed to be deleted. 7. In the result, both the appeals of the assessee are allowed.
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