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2006 (9) TMI 555
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.... The following question has been proposed for admission in these appeals: "Whether, on the facts and in the circumstances of the case, and in law, the Income Tax Appellate Tribunal is justified in confirming the order dated 23.3.1999 passed by the Commissioner of Incometax (Appeals)II, Surat, deleting penalty imposed by the Assessing Officer, on the ground that the claim for deduction u....
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....ing the income or furnishing wrong particulars of income. On the contrary, we are of the opinion that the Revenue having allowed the deduction u/s..80HH in the consecutive year u/s.143(1)(a) as well as u/s. 143(3) of the Act, it was Revenue who made the assessee to believe that it was entitled the deduction u/s.80HH of the Act. Anyhow, in the totality of the facts and circumstances of the case, we....