08.12.2015 Dr. S. Muralidhar, J.
Introduction
1. These are three Income Tax Appeals (ITAs) and four Wealth Tax Appeals (WTAs) filed by the Revenue. ITA Nos.20, 21and 24 of 2003 are in respect of Assessment Years (AY) 1988-89, 1989-90 and 1985-86 respectively. WTA Nos.3/2003, 4/2003, 5/2003 and 6/2003 are in respect of AYs 1992-93, 1990-91, 1991-92 and 1988-89 respectively.
2. It must be noted at the outset as far as the Revenue's appeals under the Income Tax Act, 1961 ('Act') are concerned, there were originally ITA Nos.20, 21 & 24 of 2003 and WTA Nos.3, 4, 5 & 6 of 2003 Page 3 of 39 nine appeals, ITA Nos. 20 to 28 of 2003. Common questions of law were framed in all the appeals by the Court on 14 th September, 2004. By the order dated 7th April, 2011, ITA Nos. 22 to 28 of 2003 were disposed of by the Court without answering the questions framed on account of the Circular dated 9th February, 2011 of the Central Board of Direct Taxes (CBDT) since the tax effect in each of the appeals was less than Rs.10 lakhs. Subsequently, review petitions were filed by the Revenue in respect of three of the appeals, i.e., ITA Nos. 23, 24 and 25 of 2003. The said review petitions were dismissed by the Court on 26 th March, 2012, after giving liberty to the Revenue to file "proper applications, if so advised."