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1977 (8) TMI 15 - GUJARAT HIGH COURT
Extract:
.......ther on facts the Explanation was applicable or not is a matter on which the Tribunal has not applied its mind and that question remains open. In the result, we answer the question referred to us in the negative, that is to say, in favour of the revenue and against the assessee. The assessee will pay the costs of this reference to the Commissioner.