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2004 (3) TMI 320 - AT - Income TaxExtract: .......round was not argued and seems to be infructuous as merely initiation of penalty proceedings is not appealable. The assessee has right to appeal against the penalty if and when it is levied. This ground of appeal is, therefore, dismissed. 25. In the result, the appeal of the Revenue stands dismissed and appeal of the assessee stands partly allowed.
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