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2005 (12) TMI 249 - AT - Income TaxExtract: .......given at that point of time. His inability to predict p a future event cannot constitute as failure so as to put the case within the ken of the proviso to section 147. We, therefore, reverse the order of the Commissioner (Appeals) on this count and decide the appeal in favour of the assessee. 12. In the result, the assessee s appeal stands allowed.
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