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1981 (4) TMI 139 - ITAT JAIPURExtract: .......rove that the explanation given by the assessee is totally false. Following the ratio of the aforementioned judgment of the Punjab and Haryana High Court we hold that as there is no positive evidence on record to show that the explanation of the assessee is totally false, and so the penalty cannot be upheld. 4. In the result, the appeal is allowed.
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