(1.) BY way of these appeals, the Revenue has challenged the order dated 21.07.2000 passed by the Income Tax Appellate Tribunal, Ahmedabad (for short "the ITAT").
(2.) WHILE admitting these appeals on 19.03.2001, the Court had formulated the following substantial questions of law: -
(3.) WE have heard learned advocate for both the parties and perused the material on record as well as the decisions relied upon by the learned advocate for the appellant. The issue No. 1 is already answered by this Court in favour of the assessee and against the revenue in the decision rendered in Tax Appeal No. 457 of 1999 relied upon by the learned advocate for the appellant. In the above decision, the Court has referred the decision in the case of Commissioner of Income -tax V. Lovely Exports (P) Ltd., : (2008) 216 CTR 195 (SC). Paragraph Nos. 7, 8 and 9 of the aforesaid decision reads as under: -