COMMISSIONER OF INCOME TAX Vs. WIPRO LTD.

JUDGEMENT

(1.) THESE appeals are directed against the common order dated June 16, 2006, rendered by the Income -tax Appellate Tribunal (for short "the Tribunal") in I.T.A. Nos. 1925, 9117/Bom/1990 and 916/M/96 whereby the Tribunal partly allowed the appeals filed by the respondent -assessee. In all the three appeals, the respondent -assessee is one and the same. Since all the three appeals are arising from the common order and the questions raised therein are similar they are being disposed of by a common judgment. Appeals before the Tribunal were arising from the orders of the Commissioner of Income -tax (Appeals) -V, Bombay, dated January 12, 1990, and November 23, 1989, and the order of the Commissioner of Income -tax (Appeals) -XXXIII, Bombay, dated October 13, 1995, respectively (for short "the appellate authority"). The appeals before the appellate authority were preferred against the three separate orders passed by the Assessing Officer (for short "the AO") dated February 10, 1989, September 27, 1989, and March 21, 1995, for the assessment years 1986 -87, 1987 -88 and 1992 -93 respectively. All the three appeals were admitted to consider the substantial questions of law, framed in the memorandum of appeals.

(2.) IN I.T.A. No. 67 of 2007, the following substantial questions of law, arise for our consideration:

(3.) IN I.T.A. No. 133 of 2007, the following two substantial questions of law arise for our consideration: