(1.) Heard Mr. Subhash Chandra Keyal, learned Senior Standing counsel, CBDT and Income Tax, NER, appearing on behalf of the appellants in these 2(two) income tax appeals. Also heard Dr. Ashok Saraf, learned senior counsel, assisted by Mr. B. Sarma, learned counsel, appearing on behalf of the sole respondent in both these income tax appeals.
(2.) The present income tax appeals being ITA No. 03/2023 and ITA No.06/2023 have been preferred by the Revenue Department under Sec. 260A of the Income Tax Act, 1961, challenging the order, dtd. 21/6/2022, passed by the Income Tax Appellate Tribunal, Guwahati Bench at Kolkata, in ITA No. GAU 232/GAU/2019 and ITA No. 359/GAU/2019.
(3.) As the above-noted income tax appeals involve identical factual and legal issues; hence, these appeals were heard together and are disposed of by this common judgment and order.