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
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 of KP Varghese vs. ITO [1981] reported in 131 ITR 597, which has been relied upon the appellant, the Hon'ble Supreme Court took cognizance of Circular dated