C.I.T. Central, Calcutta vs National Taj Traders on 27 November, 1979
In support of this, he relied on the Judgments of the Supreme Court in Commissioner of Income Tax v. National Taj Traders, , and in Tahsildar Singh v. State of U.P., . He also submitted that Section 19 was a provision prescribing the procedure and the well settled rule of construction was that a procedural provision cannot be allowed to whittle down the ambit of a substantive provision.