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1983 (3) TMI 97 - ITAT CALCUTTA-BExtract: .......iod of default prior to the issue of the notice u/s 148 has also to be taken into account for the purpose of penalty imposable u/s 271 (1) (a). In this view of the matter, we cannot sustain the order of the AAC impugned before us. Accordingly, we reverse his order and restore that of the ITO. 10. In the result, the appeal by the revenue is allowed.
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