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2004 (3) TMI 334 - ITAT DELHI-AExtract: .......erence to the instruction of the CBDT No. 1767 and have observed that the Department has not carried out necessary investigation to bring out the relevant facts in its support in the light of the instruction of the CBDT, consequently, this ground taken in this appeal also stands rejected. 28. In the result, the appeals of the Revenue are dismissed.
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