If decisions of non-jurisdictional High Courts are in conflict with each other than decision favourable to assesse must be followed

ITO Vs Upkar Retail (P.) Ltd. (ITAT Ahmedabad) We find guidance from the judgment of Hon’ble Supreme Court in the matter of CIT v. Vegetable Products Ltd. [1973] CTR (SC) 177 : [1972] 88 ITR 192 (SC) Hon’ble Supreme Court has laid down a principle that “if two reasonable constructions of a taxing provision are possible, that construction which favours the assessee must be adopted. This principle has been consistently followed by the various authorities as also by the Hon’ble Supreme Court itself. In another Supreme Court judgment, Petron Engg. Construction (P.) Ltd. & Anr. v. C...