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1975 (5) TMI 21 - AT - Income TaxExtract: .......ered in the positive. The question of limitation was not agitated in that case. Moreover, the facts of the two cases are distinguishable. Hence, we do not find any application of the ratio of the decision reported in 90 ITR 197 to the facts of the instant case. 9. In the result, the impugned assessment order is cancelled. 10. The appeal is allowed.
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