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2004 (8) TMI 358 - AT - Income TaxExtract: ....... before this Tribunal by the Revenue. Therefore, in view of second proviso to section 221(1) of the Income-tax Act, no penalty could be imposed. 16. In view of the above discussion, we do not find any infirmity in the order of the lower authority. Accordingly, we confirm the same. 17. In the result, the appeal filed by the revenue stands dismissed.
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