J. These appeals have been referred to a Bench of three learned Judges, in view of the apparent companyflict between the two judgments of Benches of two learned Judges of this Court in M.P. Cooperative Bank Limited, Jabalpur v. Additional Commissioner of Income Tax, Madhya Pradesh, Bhopal, 1996 2 SCC 541 and Commissioner of Income Tax, Bangalore v. Bangalore District Cooperative Central Bank Limited, 1998 6 SCC 129.
