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....AR J.-We have heard counsel for the assessee and the respondent. We are satisfied that the question of law involved in this appeal is fully and conclusively covered by the decision of this court in Jamnaprasad Kanhaiyalal's case [1981] 130 ITR 244. Counsel for the assessee, however, tried to distinguish this case on facts. But we are unable to see any difference. The Tribunal has recorded a ....