(1.) Since the proposed substantial questions of law are the same in both the captioned Tax Appeals, those were heard analogously and are being disposed of by this common judgment and order.
(2.) For the sake of convenience the Tax Appeal No.23/2019 is treated as the lead matter.
(3.) This Tax Appeal under Section 260-A of the Income Tax Act, 1961 (for short, 'the Act, 1961') is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Surat Bench, Surat dated 03.08.2018 in the ITA No.2666/AHD/2011/SRT for the Assessment Years 2007-08. The Appellate Tribunal vide its impugned order dismissed the appeal preferred by the Revenue & thereby affirmed the order passed by the Commissioner of Income-Tax (Appeals), Valsad in Appeal No. CIT(A)/VLS/399/09-10 dated 29.07.2011.