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2004 (7) TMI 329 - AT - Income TaxExtract: .......he penalty has been imposed in 2001, the same was beyond the limitation period. The learned CIT(A) appreciated these facts and cancelled the penalty. We do not find any infirmity in his order and while upholding the same, we dismiss the ground of appeal raised by the Revenue. 6. In the result, both the appeals directed by the Revenue are dismissed.
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