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The High Court of Allahabad declined to answer a question regarding the justification of knocking off a penalty solely based on income estimate. The Tribunal reduced the assessee's income estimate, and the penalty was deleted not only on that ground but also because there was no evidence of fraud or neglect. The Court disagreed with the Tribunal's general rule against penalizing based on income estimates but upheld the penalty deletion based on valid grounds. No costs were awarded.
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