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In the result, assessee’s appeal is allowed
Bench: Shri P.K. Bansal & Shri Amarjit Singh
10. 2. The grounds raised by the assessee are reproduced below:– “1. The learned CIT(A) erred in confirming the penalty of ` 18,00,000 under section 271(1)(c). 2 Shri Rajesh Moolchand Dayaramani 2. On the facts and in the circumstances of the case provisions of section 271(1)(c) do not apply. 3. The learned