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    <title>2013 (11) TMI 369 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the appeals filed by the assessee, stating that the penalty proceedings were not sustainable due to the lack of clarity and proper application of mind by the Assessing Officer. The penalty should be clear as to the limb for which it is levied, and in this case, the position was unclear. Consequently, the adjudication of the penalties on merits became an academic exercise, and the appeals for all six assessment years were allowed.</description>
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      <title>2013 (11) TMI 369 - ITAT MUMBAI</title>
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      <description>The Tribunal allowed the appeals filed by the assessee, stating that the penalty proceedings were not sustainable due to the lack of clarity and proper application of mind by the Assessing Officer. The penalty should be clear as to the limb for which it is levied, and in this case, the position was unclear. Consequently, the adjudication of the penalties on merits became an academic exercise, and the appeals for all six assessment years were allowed.</description>
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