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1982 (3) TMI 146 - AT - Income TaxExtract: ....... to the facts of the case, we are of the opinion that the penalty has been imposed without bringing adequate materials and facts on record and we find no application of the mind by the ITO in the present case. The order of the AAC impugned before us cannot be sustained which we hereby cancel. 6. In the result, the appeal by the assessee is allowed.
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