1991 (1) TMI 49

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..... NTHOSH DUGGAL JUDGMENT The petitioner seeks reference of the following question to this court : "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal wa .....

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..... t has come to the conclusion that, on the facts of this case, penalty proceedings should not have been initiated. In our opinion, the said conclusion is a finding of fact and no question of law aris .....

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