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2004 (3) TMI 346 - AT - Income TaxExtract: .......discussion, which would be of no consequence to the present proceedings. 21. Consequent to the above, the appeals filed by the assessee succeed and are hereby allowed. ITA No. 2925/Del/2001 22. In view of our findings on the other grounds that the penalty imposed is barred by time, nothing remains to be adjudicated even on these additional grounds.
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