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1982 (7) TMI 146 - AT - Income TaxExtract: .......contentions and counter-contentions in penalty for later filing under s. 271(1)(a) was we have annulled the assessment itself and when the very bottom of the penalty case under s. 271(1)(a) is washed out, penalty cannot stand on this basis alone penalty order deserves to be cancelled. 12. In the result, both the appeals of the assessee are allowed.
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