COMMISSIONER OF INCOME TAX Vs. SHRAVANEE CONSTRUCTIONS

JUDGEMENT

(1.) ITA No.421/2009 pertains to the assessment year 2003-04 and ITA 422/2009 pertains to the assessment year 2004-05 in respect of very same assessee and in respect of very same housing project. Therefore, they are taken up for consideration together and disposed off by this common order.

(2.) THE revenue has preferred these appeals against the order of the Tribunal, which has granted benefit of Section 80IB (10) of the Income Tax Act, 1961 (for short hereinafter referred to as the Act) on the ground that the assessee was an integral part of the construction activities.

(3.) THE substantial question of law that arise for consideration in these appeals is as under: