Hindustan Ciba-Geigy Ltd, Mumbai vs Assessee
"After due consideration I find sufficient force in the submissions of
the learned counsel of the appellant. After considering the relevant
facts and circumstances of the case I agree with the appellant that
decision of Karnataka High Court in the case of Stumpp, Schuelle &
Somappa Ltd. Vs. CIT reported in 190 ITR 152 cannot be made
applicable in the case of the appellant on account of distinguishing
facts as pointed out by learned A/R of the appellant. The case of
the appellant in may view gets full support by the following judicial
pronouncements relied upon by the appellant :