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2002 (1) TMI 261 - ITAT CALCUTTA-CExtract: ....... the Revenue would have been valid insofar as the applicability of cl. (a) or (b) of s. 275(1) is concerned but not where cl. (c) applies and as we have held above, in the present case itself cl. (c) applies which speaks the levy of penalty on 30th Sept., 1996, under s. 271B is also barred by limitation. 9. In the result, the appeals are dismissed.
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