In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed
Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad
23. Though before us, ld. Counsel for the assessee has filed a very detailed submission on this point also and relied upon a large number of decisions starting from the judgment of the Hon’ble Supreme Court in the case of ITO, Calcutta & Ors –vs.- Lakhmani Mewal Das (1976) 103 ITR 437 (SC), judgment of the Hon’ble Supreme Court