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The High Court of Karnataka allowed the petitions challenging the order of the first respondent under the Income-tax Act, 1961 for assessment years 1984-85 to 1986-87. The dispute was regarding the taxability of premium received on sale of import entitlement due to retrospective amendments. The court ruled in favor of the petitioners, stating that interest under sections 139(8) and 217 should be waived due to the retrospective amendments creating tax liability. The judgment cited different court decisions and emphasized the need for sufficient cause to waive interest. The petitions were allowed with the mentioned observations.
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