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1982 (10) TMI 49 - ITAT AHMEDABAD-CExtract: .......nt stage is fully justifiable in view of our findings in the preceding para and the decision of the Allahabad High Court which is based on reading of the relevant section 217. We find, therefore, no substance in the second appeal of the assessee, i.e., IT Appeal No. 1728 (Ahd.) of 1981, and this is also dismissed. 8. Both the appeals are dismissed.
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