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The petitioner challenged two notices under section 154 of the Income-tax Act, 1961 for assessment years 1980-81 and 1981-82. The notices questioned the allowability of interest claimed for loans taken to set up new projects. The petitioner, engaged in electricity generation and distribution, argued that the interest on capital borrowed is allowable under section 36(1)(iii). The High Court quashed the notices, stating the mistake was not apparent from the records. No costs were awarded, and the prayer for stay was refused.
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