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1982 (2) TMI 97 - ITAT BOMBAY-AExtract: .......e were not before the ITO and they were relevant materials for determining the capital accumulation in the hands of the assessee. In view of the above reasons, we hold that the Commissioner (Appeals) was quite justified in the decision that he has taken. Hence, we uphold his order for both the years. 8. In the result, the two appeals are dismissed.
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