(1.) With consent heard finally.
(2.) Shri R.L. Jain, learned Senior Counsel placed reliance on two orders passed by a Division bench of this Court on 14-3-2013 in Writ Petition No. 1565/2013, Computer Science Corporation India Pvt. Ltd. Vs. Additional Commissioner of Income Tax, Range 2 and another and in Writ Petition No. 2044/2013, Computer Science Corporation India Pvt. Ltd. Vs. Assistant Commissioner of Income Tax, Circle 2, Indore.
(3.) In the case of Commissioner of Income Tax, Kerala Vs. Manick and Sons, the Supreme Court in Paragraph 5 and in Paragraph 11 has observed thus:--