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1981 (2) TMI 94 - ITAT ALLAHABAD-AExtract: .......at whatever material is on record on the basis of which the Department has reached its conclusions with regard to the ownership of the business has been placed by the assessee himself on record. His conduct in this case is not open to challenge. 9. In the result, the order of the ld. AAC is hereby confirmed and the Departmental appeal is dismissed.
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