COMMISSIONER OF INCOME TAX Vs. HOTEL AMBASSADOR

JUDGEMENT

(1.) ALL the income-tax reference cases pertain to the same assessee and the issues are also common. Therefore, we have heard them together and proceed to dispose of them by this common judgment.

(2.) I. T. R. Nos. 22 and 23 of 1998 at the instance of the Revenue, arise out of the order of the Tribunal disposing of appeals against the assessments for the assessment years 1981-82 and 1982-83, while I. T. R. No. 20 of 1996 also at the instance of the Revenue arises out of the order of the Tribunal disposing of assessment appeal of the assessee for the assessment year 1984-85.1. T. R. Nos. 31 to 33 of 1998 at the instance of the Revenue arise out of the two separate orders of the Tribunal dismissing penalty appeals filed by the Department for the corresponding assessment years 1981-82, 1982-83 and 1984-85. The only reference case at the instance of the assessee, namely, I. T. R. No. 21 of 1998, arises out of the order of the Tribunal dismissing the assessment appeal of the assessee for the assessment year 1986-87.

(3.) FOR the sake of completeness, we give below the specific questions referred by the Tribunal for the opinion of this court :