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2009 (5) TMI 129 - ITAT DELHI-CExtract: .......with a view to examine whether the explanation was bona fide and adequate disclosure was made to arrive at the correct total income. As the whole issue is beset with controversy about the taxation of the amount, it is held that the learned CIT(A) was not justified in upholding the levy of the penalty. 7. In the result, both the appeals are allowed.
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