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1994 (3) TMI 135 - AT - Income TaxExtract: .......ourt. Otherwise, however, if the factual conditions be found to be different than as alleged by the assessee and as discussed by us above, the levy of interest is tenable to hold good. 14. In the result, the departmental appeals for all the three years are dismissed, whereas the assessee s appeals are partially allowed to the abovementioned extent.
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