(1.) THESE two appeals at the instance of department are filed against the CIT(A) orders dated 29.3.2010 and 5.10.2011, pertaining to assessment years 2007 -08 and 2008 -09 respectively.
(2.) SINCE , common issues are involved in these appeals and they pertains to the same assessee, they were heard together and disposed off by this consolidated order.
(3.) THE A.O. in the case of scrutiny assessment for assessment year 2007 -08, disallowed a sum of Rs. 64,55,563/ - and 88,689/ - by invoking the provisions of sec. 40(a)(ia) of the Act. A sum of Rs. 64,55,563/ - was disallowed by the A.O. by observing the following: -