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1983 (5) TMI 66 - ITAT CUTTACKExtract: .......lied on by the department and the instant case. 10. Considering all the facts and circumstances of the case, we come to the conclusion that the facts brought on record did not justify the levy of penalty as has been done by the revenue authorities. We therefore cancel the penalties for both the years. 11. In the result, the two appeals are allowed.
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