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The High Court of Allahabad directed the Income-tax Appellate Tribunal to refer a common question of law regarding the initiation of proceedings under section 147(b) of the Income-tax Act for assessment years 1979-80 and 1980-81. The Tribunal's decision will depend on the outcome of a pending reference for the assessment year 1977-78. No costs were awarded as the assessee did not appear.
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