2002 (11) TMI 33

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....4, 2002, passed by the Income-tax Appellate Tribunal, Delhi Bench "A", Delhi, in I.T.A. No. 1185 (Delhi) of 1994. The Revenue has proposed the following questions, stated to be substantial questions of law: "1. Whether the Income-tax Appellate Tribunal was correct in law in deleting penalty for an amount of Rs. 3,16,601 levied under section 271(1)(c)? 2. Whether the order of the Income-tax Appel....

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....s, which were encashed through proper banking channels on March 12, 1983, and March 15, 1983; the copies of the bank accounts, placed on record clearly showed that the deposits pertain to the assessment year 1984-85 and the said loans raised against pronotes were duly confirmed by the said Laxmi Chand Bhagaji. The aforenoted findings recorded by the Tribunal are essentially findings of fact, base....