16. Since we have observed that the judgment relied on by the ld.
counsel for the assessee in the case of Deepak Extrusions (P.) Ltd. (supra)
is not applicable to the facts of the assessee's case, the Supreme Court
judgment in the case of ACIT Vs. Saurashtra Kutch Stock Exchange Ltd.,
reported in 305 ITR 227 (SC) (2008) is of no assistance to the assessee.