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2000 (1) TMI 138 - AT - Income TaxExtract: ....... in default, in such cases alone, the question of levying penalty under section 221 could have arisen. Hence, we feel that the levy of penalty under section 221, in the instant case, has been totally illegal. From this angle also, we cancel the penalty order passed under section 221. 18. In the result, the appeals filed by the assessee are allowed.
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