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1985 (4) TMI 110 - ITAT COCHINExtract: .......ibunal have taken a view different from the one taken by the ITO and it is, therefore, clearly a debatable issue on which there could be two opinions. We, therefore, hold that the rectification orders are also not legally sustainable. 7. In the result, the appeals by the department are dismissed and the cross-objections by the assessee are allowed.
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