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1994 (4) TMI 93 - ITAT AHMEDABAD-BExtract: ....... distinct and different from assessment proceedings. Under the circumstances we hold that there was no conscious concealment on the part of the assessee and for a bona fide lapse on the part of a respectable lady aged over 85 years, she cannot be penalised. We accordingly uphold the findings of the CIT(A). 7. The Departmental appeals are dismissed.
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