Ltd. [2004] 267 ITR 439
and Kerala High Court in CIT v. Upasana Hospital
[19971 225 ITR 845. Considering these Judgements,
the Hon'ble Court held that 'The issue, which we are
concerned with, is a fiscal issue which is concerned
with a central statute. It is desirable that in such a
matter there should be uniformity of the judicial
opinion. Even on merits, the analogy has some
substance. We, therefore, in the light of aforestated,
decide this issue in the favour of the assessee and
against the revenue."