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1997 (12) TMI 133 - AT - Income TaxExtract: .......ed out by both the Gujarat and the Bombay High Courts in their Judgments referred to supra. 12. In the light of the above discussion, and in the totality of facts and circumstances of the case as well as in law we hold that there is no justification for the impugned penalty. The same is accordingly deleted. 13. In the result, the appeal is allowed.
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