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1985 (8) TMI 91 - ITAT AHMEDABAD-BExtract: .......e first appellate authority. It is not the case of the revenue that the Commissioner (Appeals) has not applied the correct law after appreciating the facts of the case because no submissions were made in this behalf. Therefore, we do not find any reason to set aside the order passed by the Commissioner (Appeals). 5. In the result, the appeal fails.
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