172 ITR 250;Dhakeshwari Cotton Mills vs. CIT reported in (1954) 26 ITR 775 and the decision of the Hon’ble Supreme Court in the case of PCIT vs. NRA Iron & Steel Pvt. Ltd reported in (2019) 412 ITR 161/262. 5.1 In so far as the contention of the assessee that the conditions prescribed in Explanation 2 is not satisfied