With great respect to their Lordships, we regret our inability to subscribe to the views expressed in Golaprai Hoonlal and Co.'s case [1977] 110 ITR 896 (Gauhati).
the instant case are totally different from the facts involved in the
decision of Hon'ble Gauwahati High Court in Golaprai Hoonlal & Co.
(supra). Therefore, the ratio laid down inthe said decision is not
applicable to the facts of the present case.