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....ORDER 1. The two substantial questions of law which arise in all three appeals were framed by this Court by order dated 18th January, 2006 and read as follows:- "1. Whether the Tribunal was right in holding that Sections 201(1) & (IA) of the Income Tax Act, 1961 were penal in nature and that sufficient cause was a relevant consideration while holding the assessee as an assessee in default? 2. ....
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