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1980 (9) TMI 122 - ITAT INDOREExtract: .......ppeal and cancel the penalty. 4. Thus, on the facts and circumstances of the case, since the finding given by the Tribunal is based on the appreciation of evidence of evidence on record and being a finding of fact, on question of law could be said to arise out of the order of the Tribunal. 5. Hence, the application filed by the Revenue is rejected.
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