In the result, both the appeals of the assessee are dismissed
Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12
131 ITR 597, which has been relied upon the appellant, the Hon'ble Supreme Court took cognizance of Circular dated 07-07-1964 of the Board that was issued under section 119 of the Act. Thus, the said Circular stood on a different statutory footing. In another case relied upon, i.e., Keshavji Ravji & Co. Vs. CIT [1990] reported