ORDER 1. In the present case, the High Court has not followed the direct decision of this Court on Section 80-K of the Income Tax Act, 1961 in Union of India v. Coromandel Fertilizers Ltd. [ (1976) 1 SCC 536 : 1976 SCC (Tax) 65 : (1976) 102 ITR 533] which is by a Bench of two learned Judges. The High Court has referred to two later decisions of this Court in CIT v. Patiala Flour Mills Co. (P) Ltd. [ (1979) 2 SCC 621 : 1979 SCC (Tax) 190 : (1978) 115 ITR 640] and Rajapalayam Mills Ltd. v. CIT [ (1978) 4 SCC 322 : 1979 SCC (Tax) 8 : (1978) 115 ITR 777] by a Bench of three learned Judges on Section 80-J of the Act. The latter decisions by a Bench of three Judges on Section 80-J do not say that the decision in Union of India v. Coromandel Fertilizers Ltd. [ (1976) 1 SCC 536 : 1976 SCC (Tax) 65 : (1976) 102 ITR 533] is not correct. In such a situation, it was inappropriate for the High Court to have itself treated the decision in Union of India v. Coromandel Fertilizers Ltd. [ (1976) 1 SCC 536 : 1976 SCC (Tax) 65 : (1976) 102 ITR 533] as incorrect when that is the decision directly on Section 80-K of the Act. 2. However, in these circumstances, we consider it appropriate that these matters be heard by a three-Judge Bench. 3. List the matters before a three-Judge Bench. Court Masters