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2. Whether the ITAT was justified in holding that the judgments in Prithipal Singh’s case (183 ITR 69 and 249 ITR 670) will apply even after insertion of Explanation 4 to Section 271(1)(c) of the Income Tax Act, 1961 with effect from 1.4.1976? FACTS (C.A. NO. 7115 OF 2005) For the assessment year