Govinda Choudhury & Sons vs Commissioner Of Income-Tax on 1 March, 1977
This principle has been followed by Kerala High Court in the case of CIT v. Periyar & Pareekanni Rubbers Ltd. [1973 ] 87 ITR 666 and by Orissa High Court in the case of Govinda Choudhury & Sons (supra) relied upon by Dr. Narayanan. The cases relied upon by the ITO are totally besides the point though the principles enunciated therein are subject to no dispute.