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1990 (5) TMI 71 - AT - Income TaxExtract: .......t the purpose of the penalty proceedings. Therefore, having regard to the above, we are of the view that in the peculiar facts and circumstances of this case as discussed above, no penalties were leviable on the assessee under s. 271(1)(c) for any of the assessment years in question. 21. In the result, the appeals filed by the assessee are allowed.
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