In the result, the appeal of the assessee is allowed
section 55A(a) was not justified - Held, yes - Whether in face of clear position in law, CBDT circular dated 25-11-1972 can have no application as understanding of statutory provisions by revenue as found in circular issued by CBDT is not binding upon assessee and it is open to an assessee to contend to contrary - Held, yes [Paras