How many judgments cite Subramanian and Anr. v. Siemens India Ltd. and Anr.?

541 judgments on BharatTax cite Subramanian and Anr. v. Siemens India Ltd. and Anr. (156 ITR 11), spanning 2015 to 2026.

Which sections of the Income Tax Act does Subramanian and Anr. v. Siemens India Ltd. and Anr. come up under?

It is most often cited in judgments turning on Section 80P(2)(d), Section 143(3), Section 80P(4), Section 80P(2)(a)(i), Section 263, Section 143(1).

Subramanian and Anr. v. Siemens India Ltd. and Anr.

156 ITR 11High Court1985#117 most cited

What is Subramanian and Anr. v. Siemens India Ltd. and Anr. authority for?

When there is a conflict between the decisions of non-jurisdictional High Courts, the view that favors the assessee should be preferred.

541

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2015 to 2026.

Also referred to as

Subramanian v. Siemens India Ltd. · 156 ITR 11 · conflict of High Court decisions · non-jurisdictional High Courts · assessee-favorable interpretation · tax law principle · Section 80P(2)(d) · co-operative society · judicial precedent application

Also reported as

36 CTR 197

Sections most often in play

Section 80P(2)(d)Section 143(3)Section 80P(4)Section 80P(2)(a)(i)Section 263 Section 143(1)Section 250 Section 2(19)

Issues it is cited on

section 80(2)(d)section 57(i)section 80(p)(2)(a)section 2(19)tax collected at source section 286 section 200a(1)(c)section 80p(4)section 161 section 80p(2)(c)section 80(p)(2)(d)section 200a(1)

Judgments citing Subramanian and Anr. v. Siemens India Ltd. and Anr.

Goragandhi Co-Operative Housing Society Ltd., Mumbai vs. ITO-32(1)(5), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 1024/MUM/2023[2017-18]Status: DisposedITAT Mumbai08 Jun 2023AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmangoragandhicooperative Ito-32(1)(5), Housingsociety Ltd., Room.No 729, बनाम/ Svp Road, Borivali (W) Kautilya Bhavan, Vs. Mumbai –400 051. Bkc,Bandra (E), Mumbai – 400 051. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaag3933F (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Mr. Pojan Mehta.ARFor Respondent: Ms. Kavita Kaushik.DR

Section 143(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER & SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER GoragandhiCooperative ITO-32(1)(5), HousingSociety Ltd., Room.no 729, बनाम/ SVP Road, Borivali (W) Kautilya Bhavan, Vs. Mumbai –400 051. BKC,Bandra (E), Mumbai – 400 051. "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAAAG3933F (""थ" / Respondent) (अपीलाथ" /Appellant) अपीलाथ" ओर से / Appellant by : Mr. Pojan Mehta.AR ""थ" की ओर से/Respondent by : Ms. Kavita Kaushik.DR सुनवाई की तारीख / Date of Hearing 14/06/2023 घोषणा की तारीख /Date of Pronouncement 15/06/2023 आदेश / ORD…

Sampada Nagari Sahakari Patsanstha Maryadit, Pune vs. The Principal Commissioner of Income Tax-4, Pune

Appeal is allowed in above terms

ITA 556/PUN/2023[2018-19]Status: DisposedITAT Pune29 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Shashank Deogadkar

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of 11 ITA.No.556/PUN./2023. Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Shri Siddhanath Nagari Sahkari Patsanstha Marya, Satara vs. Pr. CIT-3, Pune

Appeal is allowed in above terms

ITA 180/PUN/2023[2017-18]Status: DisposedITAT Pune26 May 2023AY 2017-18

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri J.R. ChandekarFor Respondent: Shri Deepak Garg

Section 143(3)Section 263Section 80PSection 80P(2)(d)

…laim of deduction under Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken 11 ITA.No.180/PUN./2023 against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully fo…

Solapur Zilla Madyamik Shikshak Sevakva Sahakari Pata Sanstha, Solapur vs. Principal Commissioner of Income Tax-4, Pune

Appeal is allowed in above terms

ITA 456/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Girish LaddaFor Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…laim of deduction under Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

M/S Sahakar Maharshi Shankarrao Kolhe Sakhar Kar Kamgaranchi Sah Patpedhi, Ahmednagar vs. Principal Commissioner of Income Tax, Pune-1, Pune

Appeal is allowed in above terms

ITA 454/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Sanket JoshiFor Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…laim of deduction under Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Pradeshik Manorugnalaya Karmachary Sahakari Patha Sanstha, Pune vs. Principal Commissioner of Income Tax-4, Pune

Appeal is allowed in above terms

ITA 453/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of 11 ITA.No.453/PUN./2023 Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Pune District Supervision Co- Operative Societies Ltd, Pune vs. The Principal Commissioner of Income Tax-3, Pune

Appeal is allowed in above terms

ITA 428/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of 11 ITA.No.428/PUN./2023. Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Shivkrupa Nagari Sahakari Pata Sanstha Ltd, Pune vs. The Principal Commissioner of Income Tax-4, Pune

Appeal is allowed in above terms

ITA 409/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of 11 ITA.No.409/PUN./2023 Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Poona Post and Telecom Co. Op. Credit Society Ltd., Pune vs. The Principal Commissioner of Income Tax-4, Pune

Appeal is allowed in above terms

ITA 394/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of 11 ITA.No.394/PUN./2023. Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Sudhakarpanth R. Paricharak Gramin Bigarsheti Pat Sanstha, Solapur vs. The Principal Commissioner of Income Tax -4, Pune

Appeal is allowed in above terms

ITA 381/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri S.N. PuranikFor Respondent: Shri Sardar Singh Meena

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…Sec.80P(2)(d) of the Act. Backed by the 11 ITA.No.381/PUN./2023 aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Pune Vibhag Madhyamik Shikshak Patsanstha Ltd, Satara vs. The Principal Commissioner of Income Tax -3, Pune

Appeal is allowed in above terms

ITA 377/PUN/2023[2018-19]Status: DisposedITAT Pune25 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

…Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of 11 ITA.No.377/PUN./2023 Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully follow the view taken by th…

Gramin Sewa Sahakri Samiti Maryadit, Dharsiwa, Raipur vs. Income Tax Officer 1(2), Raipur

ITA 89/RPR/2023[2011-12]Status: DisposedITAT Raipur24 May 2023AY 2011-12

Bench: Shri Ravish Sood

For Appellant: None (written submissions)For Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(2)Section 143(3)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

…आयकर अपील"य अ"धकरण "यायपीठ “एक-सद"य” मामला रायपुर म" IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH “SMC”, RAIPUR "ी रवीश सूद, "या"यक सद"य के सम" BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER Sl. ITA No. Name of Appellant Name of Asst. Year No. Respondent 1. 87/RPR/2023 Gramin Sewa Sahakari The ITO-1(2), 2017-18 Samiti Maryadit Raipur (C.G.) Village- Gaurbhat, Arang, Raipur (C.G.)-493 441 PAN : AAAAG9799D 2. 88/RPR/2023 Gramin Sewa Sahakari The ITO-1(1), 2017-18 Samiti Maryadit Raipur (C.G.) Village-Champajhar, Raipur-493 992 PAN : AABAG0198B 3. 89/RPR/2023 Gramin Sewa Sahakari The ITO-1(2), 2011-12 Samiti Maryadi…

Gramin Sewa Sahakari Samiti Maryadit, Champajhar, Raipur vs. Income Tax Officer-1(1), Raipur

ITA 88/RPR/2023[2017-18]Status: DisposedITAT Raipur24 May 2023AY 2017-18

Bench: Shri Ravish Sood

For Appellant: None (written submissions)For Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(2)Section 143(3)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

Gramin Sewa Sahakari Samiti (Maryadit), Gaurbhat, Raipur vs. Income Tax Officer-1(2), Raipur

ITA 87/RPR/2023[2017-18]Status: DisposedITAT Raipur24 May 2023AY 2017-18

Bench: Shri Ravish Sood

For Appellant: None (written submissions)For Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(2)Section 143(3)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

Sholapur District Police Employees Credit Co- Operative Siciety, Solapur vs. The Principal Commissioner of Income Tax-4, Pune

Appeal is allowed in above terms

ITA 376/PUN/2023[2018-19]Status: DisposedITAT Pune15 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…laim of deduction under Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken 11 ITA.No.376/PUN./2023. against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon’ble High Court of jurisdiction, we respectfully f…

Solapur Zilha Prathamik Shikshak Sahakari Sanstha Niyamit, Solapur vs. Principal Commissioner of Income Tax, Pune-4, Pune

Appeal is allowed in above terms

ITA 370/PUN/2023[2018-19]Status: DisposedITAT Pune15 May 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: -None-For Respondent: Shri Sardar Singh Meena

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

…laim of deduction under Sec.80P(2)(d) of the Act. Backed by the aforesaid conflicting judicial pronouncements, we may herein observe, that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non- 11 ITA.No.370/PUN./2023 Solapur Zilha Prathamik Shikshah Sahakari Sanstha Niyamit, Solapur jurisdictional High Court‟s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronounc…

Jansevak Co-Op Credit Society Ltd, Mumbai vs. Income Tax Officer, Ward 27(1)(5), Mumbai

ITA 639/MUM/2023[2014-15]Status: DisposedITAT Mumbai09 May 2023AY 2014-15

Section 143(1)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…iety on its investments held with a cooperative bank would be eligible for claim of deduction under Sec.80P(2)(d) of the Act. We find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of non-jurisdictional High Court’s, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon‟ble High Court of jurisdiction, we respectfully follow the view taken by the…

Jansevak Co-Op Credit Society Ltd, Mumbai vs. Income Tax Officer, Ward 27(1)(5), Mumbai

ITA 638/MUM/2023[2015-16]Status: DisposedITAT Mumbai09 May 2023AY 2015-16

Section 143(1)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

Golden Square Chs Ltd., Mumbai vs. ITO-22 (1)(5), Mumbai

In the result, the two appeals filed by the assesee are allowed

ITA 572/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 May 2023AY 2012-13

Bench: Shir Pavan Kumar Gadaleita No. 572 & 573/Mum/2023 (A.Y: 2012-13 & 2013-14) Golden Square Chsltd., Vs. Ito – 22(1)(5),Roomno. Cst Road, Sunder Nagar 323,3Rdfloor,Piramal Kalina, Santicruz (E) Chamber,Lalbaug, Mumbai. 400098 Parel, Mumbai.400012 Pan/Gir No. : Aaaag2527M Appellant .. Respondent Appellant By : Shri Kunal Lunawat & Shri Rajendra Kumar Jain.Ar Respondent By : Shri Rajendra Chandekar.Dr Date Of Hearing 02.05.2023 Date Of Pronouncement 04.05.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: These Are The Two Appeals Filed The Assessee Against The Different Orders Of The National Faceless Appeal Centre (Nfac)/Cit(A), Delhi Passed U/S 250 Of The Act.

For Appellant: Shri Kunal Lunawat, &For Respondent: Shri Rajendra Chandekar.DR

Section 143(1)Section 154Section 154(7)Section 250Section 80PSection 80P(2)(d)

…for claim of deduction under Sec. 80P(2) (d) of the Act. We find that as held by the Hon'ble High Court of ITA No. 572 & 573/Mum/2023 Golden Square Co Op HSG Society, Mumbai. Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of nonjurisdictional High Court's, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon'ble High Court of jurisdiction, we respectfully follow the view taken by the…

Shree Durgamata Co-Operative Credit Soc Ltd., Mumbai vs. CIT (A) - NFAC, Delhi

In the result the appeal filed by the appeal is allowed

ITA 414/MUM/2023[2017-18]Status: DisposedITAT Mumbai03 May 2023AY 2017-18

Bench: Shir Pavan Kumar Gadaleshree Durgamata Co-Op Vs. Cit(A)-Nfac, Society Ltd, Room.No 245-A, Room.No.52,Khandkebldg. North Block, No.12,Jksawantmarg, New Delhi, Opp Shivaji Mandir, Delhi-110001. Dadar (W), Mumbai-400028. Pan/Gir No. : Aagas9038K Appellant .. Respondent Appellant By : Shri.Gautam Gokhale.Ar Respondent By : Shri.Rajendra Chandekar.Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 01.05.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi/Cit(A) Passed U/Sec 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Gautam Gokhale.ARFor Respondent: Shri.Rajendra Chandekar.DR

Section 144Section 80PSection 80P(2)(a)Section 80P(2)(d)

…ty on its investments held with a cooperative bank would be eligible for claim of deduction under Sec. 80P(2) (d) of the Act. We find that as held by the Hon'ble High Court of Bombay in the case of K. Subramanian and Anr. Vs. Siemens India Ltd. and Anr (1985) 156 ITR 11 (Bom), where there is a conflict between the decisions of nonjurisdictional High Court's, then a view which is in favour of the assessee is to be preferred as against that taken against him. Accordingly, taking support from the aforesaid judicial pronouncement of the Hon'ble High Court of jurisdiction, we respectfully follow the view taken by the…