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1988 (9) TMI 43

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.... the following question of law: "Whether, on the facts and in the circumstances of the case, the Tribunal was justified legally in holding that no penalty under section 271(1)(a) of the Income-tax Act, 1961, is leviable in the case of the assessee, a registered firm, because it had no tax liability in terms of the Explanation to section 271(1)(a) and that the provisions of section 271(2) did not ....