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1985 (11) TMI 93 - ITAT DELHI-EExtract: ....... The reliance placed by the learned Departmental Representative on decision reported in (1976) 103 ITR 455 and (1970) 77 ITR 637 (Cal) does not help the case of the Department in view of the facts found in the present case which are wholly different from the facts which prevailed in the above mentioned two cases. 6. In conclusion, the appeals fail.
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