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1991 (1) TMI 67 - KARNATAKA HIGH COURT
Extract:
.......re is not the sole test in every case. The facts and circumstances of each case, read in the background of the assessee s business and other activities, will have to be examined. Consequently, we are of the view that the answer to the question referred to us will have to be in the affirmative and against the Revenue. Reference answered accordingly.