Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena
246 in paragraph 8 had held as under : "8. Having heard the learned Counsel for the parties, we are satisfied that the internal guidelines issued by the Central Board of Direct Taxes, as urged by the learned Counsel for the Assessee, bereft of the statutory provisions in Section 153D of the Act cannot bind the approving Authority, namely, the Joint