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1991 (11) TMI 107 - AT - Income TaxExtract: .......satisfied. The Gauhati High Court has also held in the case of Metal Stores v. CIT 1990 89 CTR (Gauhati) 132 that protective penalties cannot be levied or sustained. We, therefore, hold that the assessee was not liable for any penalty under sections 271(1)(b), 273 or 271(1)(c) of the Income-tax Act, 1961. 9. In the result, the appeals are dismissed
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