(1.) Both these appeals have been preferred under Sec. 260A of the Income Tax Act, 1961 ( "the Act ") challenging the order dtd. 20/1/2017 passed by the Income Tax Appellate Tribunal, Bench 'F ', Mumbai ( "ITAT "), for the assessment years 2009-10 and 2010-11.
(2.) The facts and issues arising in both these appeals are identical, however, for the sake of deciding the issue, reference is being made to the facts in I.T.A. No.1016 of 2018.
(3.) As many as fve questions of law have been framed for our consideration: