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1979 (4) TMI 45 - ITAT CALCUTTA-AExtract: .......e not applicable to the loan which was given in the month of July 1970. It was therefore wrong on the part of the ITO to have included it on that ground. We therefore uphold the order of the AAC though on a different ground. The question of consideration of the additional evidence before the AAC therefore does not arise. 9. The appeal is dismissed.
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