The judgment of the court was delivered by

TULZAPURKAR J.--Two contentions under a scheme called " Tax Credit Certificate (Excise Duty on Excess Clearance) Scheme, 1965 " framed by the Central Government under s. 280ZD of the I.T. Act, 1961, which were negatived by the High Court, have again been pressed by the appellant company before us in these appeals but after hearing counsel for the appellant company