(1.) AS common question of law and fact arise in both these appeals and as such arise out of the common judgement and order passed by the Income Tax Appellate Tribunal (hereinafter referred to as "the ITAT"), both these appeals are disposed of by this common judgement and order.
(2.) BOTH these appeals have been preferred by the revenue challenging impugned common judgement and order passed by the learned ITAT in ITA Nos.1546/Ahd/2010 and 1547/Ahd/2010 dated 5/4/2013 with respect to AY 2007 -2008 by which the ITAT has allowed the said appeals preferred by the respondents assessee on altogether a different ground which was neither canvassed before the Assessing Officer nor before the CIT(A).
(3.) FACTS leading to both these appeals in nutshell, are as under : -