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1991 (11) TMI 108 - ITAT CALCUTTA-DExtract: .......penalty are satisfied. The Guwahati High Court has also held in the case of Metal Stores vs. CIT (1990) 89 CTR (Gau) 132 that protective penalties cannot be levied or sustained. We, therefore, hold that the assessee was not liable for any penalty under ss. 271(1)(b), 273 or 171(1)(c) of the IT Act, 1961. 9. In the result, the appeals are dismissed.
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