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1997 (3) TMI 12 - SC - Income TaxHigh Court was justified in holding that the assessee who had been previously assessed, had been taken erroneously to be a "new assessee", and penal interest had been charged on the basis, that it had not submitted an estimate under section 212(3). It was a patent mistake since the assessee was not obliged to submit an estimate under section 212(3) of the Income-tax Act. The application for rectification of the assessment order was maintainable under section 154
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