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1985 (1) TMI 143 - AT - Income TaxExtract: .......ssee may not have been aware of the said amendment. The decision of their Lordships of the Patna High Court in P.A. Patel s case is wholly in favour of the assessee. Respectfully, following the said decision, we hold that the levy of penalty was not correct even on facts. 8. As per reasons mentioned above, the appeal of the department is dismissed.
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