Court held that the Department’s submission that as a large number of proceedings were pending in which substantial tax amounts were involved on such issue, the Court needed to take a different view of the matter including referring the issue for consideration of a larger Bench, could not be accepted. Such approach would not bring about any concrete conclusion as such question of law was pending determination before the Supreme Court, arising not only from the decision of this court, but also from the decisions of the other High Courts. It would be appropriate and desirable to await the decision of the Supreme Court in the pending proceedings. The question of law which would touch not only the present proceedings, but hundreds of other pending proceedings was at large before the Supreme Court. The Supreme Court was seized of the proceedings in which it would decide on the correct purport and the determination on interpretation of the interplay between section 144C and section 153. In so far as the interim relief in the present petition was concerned, the court similarly placed assessees as the assessee herein had succeeded before other High Courts and proceedings arising from such decisions were pending before the Supreme Court. The orders of the High Courts setting aside the assessment orders were not stayed by the Supreme Court. As and by way of interim relief, the ad interim order shall continue to operate till the final disposal of the petition. Liberty was granted to the parties to apply, in the event orders relevant to the issue of law as involved were passed, on a final decision being rendered by the Supreme Court.(AY. 2020-21)