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1994 (10) TMI 85 - AT - Income TaxExtract: .......anation has been tendered in that letter of the assessee and the assessee has merely requested for keeping the penalty proceedings in abeyance till the decision of the CIT(A). Therefore, the contention of the assessee that explanation had been flied is without force. 17. In view of the above discussions, the appeals for both the years are dismissed
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