(1.) HEARD the learned counsel for the appellant and the learned counsel for the respondent. In the above appeals, the following substantial question of law arises :
(2.) PERUSED the judgment of the learned Tribunal wherein it is observed as under :
(3.) MR . Suresh Kumar, learned counsel for the appellant, strongly relied upon the judgment of the Supreme Court in the case of Pandian Chemicals Ltd. vs. CIT (2003) 183 CTR (SC) 99 : (2003) 262 ITR 278 (SC) and also the judgment of the Madras High Court in the case of CIT vs. Pandian Chemicals Ltd. (1998) 147 CTR (Mad) 5 : (1998) 233 ITR 497 (Mad).