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1976 (3) TMI 76 - AT - Income TaxExtract: .......nally fixed in the assessment, no inference of dis-honesty could by drawn. We think that the ratio decided of the two cases cited by the learned counsel of the assessee directly applies to the facts of this case. The penalty is, therefore, also against the provisions of lrw. It is cancelled. 16. In the result, the appeal of the assessee is allowed.
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