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1997 (6) TMI 52 - ITAT DELHI-EExtract: ....... under consideration and the revenue authorities went wrong in relying upon such circumstances. For the aforesaid reasons, we hold that Explanation 5 to section 271(1)(c) of the Income-tax Act, 1961 is not applicable as the case was covered by clause (i). The penalty imposed, therefore, is hereby cancelled. 13. In the result, the appeal is allowed.
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