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1993 (12) TMI 100 - AT - Income TaxExtract: .......Therefore, on a consideration of all relevant facts and circumstances of the case, we are of the view that there was no occasion even for initiation of proceedings under section 271(1)(c) much less imposition of the penalty thereunder. We, therefore, cancel the penalty levied and allow the assessee s appeal. 9. In the result, the appeal is allowed.
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