ORDER

1. All these matters are covered by the pronouncement of this Court in Second I. T.O.

versus

Stumpp Schuele & Somappa (P) Ltd.((1991) 187 ITR 108 (SC))

2. We do not consider it necessary or appropriate to entertain any contention suggesting that reasoning in the said judgment suffers from infirmities. It is as important that law be certain as it is correct. These appeals are, accordingly, dismissed but without any order as to costs.

Annexure

BEFORE K.N. SINGH, K. JAGANNATHA SHETTY AND KULDIP SlNGH, JJ.

SECOND INCOME TAX OFFICER AND ANOTHER

Versus

STUMPP SCHUELE AND SOMAPPA (P) LTD. .

Decided on 14-9-1990

ORDER

These appeals, by leave of this Court under Article 136 of the Constitution, are directed against the judgment and order of the High Court of Karnataka dated 3-7-1975 (Second ITO v. Stumpp Schuele and Somappa (P) Ltd.{(1977) 106 ITR 399}, allowing the writ petitions filed by the respondent-assessee and quashing the notices issued under Sections 8 and 16 of the Companies (Profits) Surtax Act, 1964.

After hearing learned counsel for the parties, we do not find any good reason to interfere with the view taken by the High Court. A similar view has been taken by a number of High Court