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10(2)(vi) of the Act of 1922. As observed by Shah J. in Commissioner of Income-tax v. Bhanji Lavji,(1) section 34(1)(a) of the Act of 1922 (corresponding to section 147'(a) (1)79 I,T.R. 582. S.C. of the Act of 1961) does not cast a duty upon the assessee to instruct the Income