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1984 (12) TMI 96 - ITAT CALCUTTA-CExtract: .......d an ad hoc penalty of Rs. 765 on the assumption as if no guidance has been laid down in the section for the purpose of imposition of the penalty. Prima facie, the above action of the ITO is contrary to law and as such it is not possible for us to sustain it. 10. In the result, the order of the learned AAC is sustained though for different reasons.
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