2006 (8) TMI 104

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..... inimum penalty - ITR 253/1995 - - - Dated:- 2-8-2006 - R.S. GARG and M.R. SHAH JJ. JUDGMENT The judgment of the court was delivered by R.S.GARG J. The Income Tax Appellate Tribunal, Ahmedabad Bench "C" has made this Reference for its answer by the High Court on the following question : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in uph .....

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..... fter the raid was conducted and penalty was imposed, a Return came to be filed and it was revised almost after 2 years of its filing. He submits that, in the quantum appeal between the same parties, the Tribunal has made certain observations against the interests, and observed that the action of the assessee was unfair. He submits that present is not a case where no penalty could be imposed. 3. .....

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