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The High Court of Allahabad reviewed a case involving penalty levied under section 271(1)(c) of the Income-tax Act for an assessment year of 1966-67. The Tribunal canceled the penalty, citing precedents from the Punjab and Haryana High Court and the Delhi High Court. The High Court directed the Tribunal to reconsider the case in light of recent Supreme Court decisions explaining the effect of the Explanation to section 271(1)(c). The reference was returned to the Tribunal for further consideration.
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