(1.) BOTH the appeals have been filed by the Department against the common judgment and order dated 30.06.2005 passed by the Income Tax Appellate Tribunal, Lucknow in Second Appeal Nos. 455/Luc/2001 and 457/Luc/2001, for the assessment years mentioned above.
(2.) ON 28.11.2005, both the appeals were admitted by a Coordinate Bench on the following substantial question of law: -
(3.) WITH this background, Sri D.D. Chopra, learned Standing Counsel for the Income -tax Department justified the impugned order passed by the AO. He also submits written submissions.