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1987 (8) TMI 135 - ITAT COCHINExtract: .......n in the grounds of appeal that the penalty proceedings were initiated only on 31-12-1985, but the CIT (Appeals) has stated that they were initiated at the time of passing the assessment order on 28-12-1984. This has not been denied by the assessee s representative. 7. In the result, we confirm the order of the CIT (Appeals) and reject this appeal.
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