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2000 (11) TMI 527 - CEGAT, MUMBAIExtract: ....... argued by Shri Deepak Kumar limitation as such may not be applicable to levy of penalty, however, the precedent decision cited by the appellant may be in favour of the assessee because in both cases result is the same. I therefore constrained to follow the precedent decision. The appeal is allowed with consequential relief if any according to law.
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