Commissioner Of Income-Tax vs Punjab Financial Corporation on 4 December, 2001
21. We are further of the view that the observations made in Shahzedanand Charity Trust's case [1997] 228 ITR 292 (P & H), that the view expressed by the Gujarat High Court in CIT v. Gujarat Oil and Allied Industries [1993] 201 ITR 325, is similar to the one expressed by this court in CIT v. Jaideep Industries [1989] 180 ITR 81 is based on an incorrect reading of the judgment of Gujarat Oil and Allied Industries case [1993] 201 ITR 325 (Guj), because the Gujarat High Court had, in fact, dissented from the view expressed in Jaideep Industries case [1989] 180 ITR 81 (P & H).