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2003 (3) TMI 286 - AT - Income TaxExtract: .......ssee cannot be penalized. In view of the discussion above, ground No. 1 of the appeal filed by the revenue fails and is hereby dismissed. 20. In view of the above discussion, the appeals of the revenue while fail on ground No. 1 succeed on ground No. 2 and are, therefore, partly allowed. 21. In the result, the appeals of revenue are partly allowed.
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