Commissioner Of Income Tax vs M/S Kelvinator Of India Ltd. on 19 January, 2015

*         IN THE HIGH COURT OF DELHI AT NEW DELHI
+                  ITA No. 165/2001
                                         Reserved on:13th October, 2014
%                                    Date of Decision: 19th January, 2015

COMMISSIONER OF INCOME TAX             ....Appellant
            Through Mr. N.P. Sahni, Sr. Standing Counsel
                    and Mr. Nitin Gulati, Jr. Standing
                    Counsel.
        Versus

M/S KELVINATOR OF INDIA LTD.             ...Respondent
            Through    Mr. Ajay Vohra, Sr. Advocate with
                       Ms. Kavita Jha and Mr. Vaibhav
                       Kulkarni, Advocates.
            ITA No. 170/2001

COMMISSIONER OF INCOME TAX             ....Appellant
            Through Mr. N.P. Sahni, Sr. Standing Counsel
                    and Mr. Nitin Gulati, Jr. Standing
                    Counsel.
        Versus

M/S KELVINATOR OF INDIA LTD.            ...Respondent
            Through   Mr. Ajay Vohra, Sr. Advocate with
                      Ms. Kavita Jha and Mr. Vaibhav
                      Kulkarni, Advocates.
CORAM:
HON'BLEMR. JUSTICE SANJIV KHANNA
HON'BLE MR. JUSTICE V. KAMESWAR RAO

SANJIV KHANNA, J.

Revenue has preferred these two appeals under Section 260A of the Income Tax Act, 1961 (Act, for short) in the case of Kelvinator of India Ltd. (now known as Whirlpool India Ltd.). These appeals pertain to assessment years 1989-90 and 1990-91. The orderimpugned, common to both appeals, passed by the Income Tax Appellate Tribunal (Tribunal, for short) is dated 30th August, 2000.

2. By order dated 6th December, 2001, the fo