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Bench: HON'BLE MRS. JUSTICE SABINA,HON'BLE MR. JUSTICE SUSHIL KUKREJA
119 to ensure a uniform and proper administration and application of the Income-tax Act.” 16. Learned counsel for the respondent has also placed reliance on the judgment of Hon’ble Supreme Court in Mercantile Bank Ltd. versus Commissioner of Income-Tax, (2006) 283 ITR 84 (SC), wherein it has been held as under:- “7. Although the 1952 circular