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
55 Taxman 497 (SC) ], which is as under: "The decisions of the Supreme Court in Navnit Lal C. Javeri v. KK Sen, Appellate Assistant Commissioner of Income-tax [1965] 56 ITR 198 (SC) and Ellerman Lines Ltd. v. Commissioner of Income-tax [1971] 82 ITR 913 (SC) must be considered to be the exceptional ones". 4.6 In the case