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1995 (9) TMI 91 - ITAT AHMEDABAD-CExtract: .......m of penalty is concerned. Therefore, while we uphold the imposition of penalty under section 221 of the Income-tax Act, on the assessee, we direct that looking to the facts and circumstances of the case, the penalty may be reduced to Rs. 1,50,000 only. The assessee gets relief of Rs. 1,50,000. 13. The appeal filed by the assessee is partly allowed
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