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Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar
u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission