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1986 (8) TMI 85 - ITAT AHMEDABAD-AExtract: .......see that atleast for these years the levy of penalty is illegal, yet this aspect is very material as it favours of the stand that the assessments were made on estimated basis and without there being conclusive finding regarding concealment of income. 4.5. We uphold, the order passed by the AAC of IT. 5. In the result, all the appeals are dismissed.
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