Commissioner vs Cornerstone on 15 May, 2008
42. Here also various statutory
provisions and judicial pronouncements cited before us were not cited
before the High Court. The High Court, therefore, did not have the
benefit of examining such judicial pronouncements. Even otherwise we
have given detailed reasons for holding the belief that we have
expressed in this judgment. We are unable to persuade ourselves to
follow Delhi High court in above mentioned cases of Commissioner of
Income-Tax vs. Nanak Ram Jaisinghania (supra) and in the case of
Commissioner of Income-Tax, Delhi-II vs. Manglam Ricinus Ltd.
(supra).