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The appeal by the Revenue for the asst. yr. 1972-73 against the order of the AAC was dismissed by the ITAT Jaipur. Re-assessment under s. 147, r/w s. 148 is not a regular assessment under s. 143 or s. 144. Penalty proceedings under s. 273 cannot be imposed in re-assessment proceedings. The appeal was dismissed as no penalty can be levied in such circumstances.
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