{field 10} {field 4}

So far as judgment delivered in the case of Honda Siel Power Products Ltd. v. Commissioner of Income Tax,Delhi, 2008 (221) E.L.T. 11 (S.C.), is concerned, there also the Tribunal had not considered certain material which was very much on record and thereby it committed a mistake which was subsequently rectified by considering and appreciating the evidence which had not been considered earlier. As stated hereinabove, in the instant case, the position is absolutely different.