(1.) THESE three T. R. Cs. are disposed of by a common judgment as the issue involved is common to all the TRCs.
(2.) THE brief facts are as follows :
(3.) TO consider the arguments of the counsel for the Revenue as well as the assessee-respondent, it is necessary to refer to G. O. Ms. No. 520 dated July 20, 1988 and it reads as follows :