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1987 (12) TMI 58 - ITAT AHMEDABAD-AExtract: .......e was not taxable in the hands of the assessee under section 64(2) after the partial partition effected on 12th November, 1974. 21. we also hold that the decision in the case of P. K. Kochammu Amma would not apply to the facts of the present case. 2. We accordingly cancel the penalties for both the years under consideration and allow these appeals.
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