(1.) I.T.A.Nos. 16 & 17 of 2004 involve the same question of law and facts, thus, they are being considered and decided by this common order.
(2.) The instant appeals i.e. I.T.A.Nos. 16 & 17 of 2004 arise from the orders dated 22.9.2003 & 22.9.2003 passed by the Income Tax Appellate Tribunal (for short "the ITAT") in IT (SS) A No.47/Nag/2000 (Block period 1.4.1987 to 14.11.1997) & IT (SS) A No.46/Nag/2000 (Block period 1.4.1987 to 14.11.1997), respectively.
(3.) I.T.A.No.16 & 17 of 2004 were admitted on 23.04.2009 on the following substantial question of law :