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1996 (7) TMI 189 - AT - Income TaxExtract: .......e time were not explained either before the AO or the CIT(A). In these circumstances, the AO has rightly initiated penalty proceedings and has imposed the penalty under s. 271(1)(a) of the Act and 271(2) of the Act. We, accordingly, set aside the order of the CIT(A) and restore that of the AO. 5. In the result, the appeal of the Revenue is allowed.
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