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1981 (2) TMI 93 - ITAT ALLAHABADExtract: .......rits. Merely because the assessee held an opinion, which did not find favour with the IT authorities, he cannot be held guilty of the default under s. 212 (3A) and penalised in term of cl.(c) of s. 273 of the IT Act, 1961. The penalty imposed is, in our opinion totally unjustified and, we therefore, delete it. 9. In the result, the appeal succeeds.
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