133 (Magazine Section) and having noticed diametrically opposite views expressed in two decisions of the Tribunal - one reported in 39 I.T.D. 432 Butwelded Tools (P) Ltd. Vs. Asstt. Commissioner of Income-tax and the opposite decision rendered by the Hyderabad Bench in V.V. Trans Investment (P) Ltd. Vs. Income-tax Officer (42 ITD 242) we are of the opinion