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1979 (8) TMI 97 - AT - Income TaxExtract: .......ee against the show cause notice issue by the ITO. Since the show cause notice was not considered by the ITO the assessee was not given a reasonable opportunity off being heard. In this view of the matter the AAC was justified in deleting the penalty. No interference is called for. 12. In the result, both these Departmental appeals stand dismissed.
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