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1991 (5) TMI 112 - ITAT DELHI-AExtract: .......he authorities below were not justified in confirming the levy of tax when there was no liability to tax at all. Merely on the basis of highly technical interpretation of section 140A of the Income-tax Act, without having regard to the pith and substance and the care and object of section 140A. We, therefore, cancel the penalty and allow the appeal
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