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1991 (2) TMI 185 - ITAT DELHI-A
Extract:
.......ry for us to express our considered opinion on these aspects as they were gone into by the CIT and were hotly contested by the parties before us although we are upholding his action under s.263 on other points. 8. In the result, and subject to the foregoing findings, the appeals filed by the assessee are to be treated as having been partly allowed.