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2001 (3) TMI 765 - CEGAT, MUMBAIExtract: ....... said policy. Mr. Choubey spent quite sometime in putting this across. I observe that this issue was not forming part of the deliberations in either proceeding at lower levels. The Revenue cannot be permitted to make a fresh ground at this second appellate stage. 5. emsp I find that the impugned order sustains. The appeal from Revenue is dismissed.
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