The Hon’ble Supreme Court on an SLP filed by the Department observed that having admitted the first question of law, the High Court seems to have declined to admit the appeal on the second substantial question of law as proposed by the Revenue, on the premise that the same is covered by Finance Act, 1984, Circular No. 387 dated 6-7-1984 issued by the Income Tax Department. Thus, it was observed that it will be in fitness of things if the High Court also looks into the second question of law in circumstances where Revenue has raised the point that the said Circular would not apply. The Hon’ble Court however clarified that it will be for the High Court to take the final call as regards the merits of the said substantial questions of law.