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1987 (11) TMI 95 - ITAT AHMEDABAD-AExtract: .......hat such approach would be relevant only in assessment proceedings and not in penalty proceedings. In view of this, even the decisions relied upon by the Commissioner (A) do not help the case of the Revenue. 7.4. We, therefore, set aside the order passed by the Commissioner (A) and cancel the penalty levied. 8. In the result, the appeal is allowed.
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