In the result, the assessee’s appeals are allowed for statistical purposes
Bench: Shri Sanjay Arora & Ms. Kavitha Rajagopal
1 (SC); Sree Bhagavathi Textiles Ltd. v. CIT[2000] 244 ITR 496 (Ker)). The only opinion therefore on record is that by the Tribunal in Santhimadom Herbal City Trust (supra), which we have, for the reasons afore-stated, found as not commending itself for adoption, with there being no estoppel against law. The Tribunal, in rendering it’s said decision