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2003 (3) TMI 299 - ITAT VISAKHAPATNAMExtract: .......ction of the Department . In the present case, liability is traced to the concerned provision of the Finance Act and not to any circular or instruction of the Department. So, I am of the view that the said decision of the Tribunal is distinguishable well on facts. For the above reasons, I set aside the order of the CIT(A). 6. The appeal is allowed.
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