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The High Court of Patna considered a case where the Income-tax Appellate Tribunal canceled a penalty imposed on an assessee for filing a revised return. The Tribunal justified its decision based on the fact that the assessment was initially completed under section 143(1) of the Income-tax Act, and a revised return was filed later. The Court ruled in favor of the assessee, stating that the revised return could be considered valid under section 139(5) of the Act.
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