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1992 (6) TMI 97 - AT - Income TaxExtract: .......efore, we are satisfied that the facts of the assessee s case do not attract Explanation 1 to section 271(1)(c) of the Income Tax Act, 1961. 8. In the light of the judgments supra, we are satisfied that penalty under section 271(1)(c) is not warranted. Accordingly, the order of the CIT(A) is upheld. 9. In the result, the cross appeals are dismissed
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