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2010 (9) TMI 97 - ALLAHABAD HIGH COURTLevy of penalty - period of limitation - section 275(1) - penalty on the basis of ITAT order in rectification application dated 28.2.2005 - Held that: - The order dated 28.2.2005 was related to correction in the certificate dated 28.7.1999 in respect of interest only under the Scheme. It was irrelevant for considering the limitation to levy of penalty. This limitation had to be calculated on the basis of the order of the Tribunal dated 24.9.2004 dismissing the appeal in reassessment proceeding
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