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1993 (3) TMI 158 - ITAT DELHI-DExtract: .......hheld by Shri Mukesh Kumar in his own interest. Thus case is fully covered by proviso to Explanation 1 mentioned above. On totality of facts and circumstances and for reasons given above I hold that present is not a fit case for levy of penalty under section 271(1)(c) of Income-tax Act. I cancel the same. In the result, assessee s appeal is allowed
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