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2005 (2) TMI 473 - AT - Income TaxExtract: .......nclusion that the assessee has committed or omitted either of the ingredients, of s. 271(1)(c) of fact. Something more is required to be proved by the Department. In my opinion, the penalty is not leviable on any of the above addition. Hence, the penalty is set aside. The appeal of the assessee is accepted. 11. In the result, the appeal is allowed.
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