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1981 (9) TMI 164 - ITAT CALCUTTA-EExtract: .......g as stated hereinbefore, we further hold that the second condition laid down in s. 147(a)/147(b) of the Act that income chargeable to tax has escaped assessment or has been under assessed for each of the years under consideration is also not satisfied in the present case. 11. In the result, the appeals by the revenue fail and are hereby dismissed.
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