(1.) The following common substantial questions of law, on which these appeals were admitted, are involved in these appeals, hence they are being disposed of by a common judgment:-
(2.) These appeals pertain to the returns filed by the appellant for the years 1997-98, 1998-99 and 2000-2001. Questions of law are same. Except for difference in dates facts being almost identical/ similar, for the purpose of adjudication of these appeals, facts pertaining to the year 1997-98 are being referred to.
(3.) Appellant is a partnership firm having an industrial undertaking, an oil mill unit in Damtal, within the State of Himachal Pradesh. It also has other businesses of petrol pumps, carriage contacts of Indian Oil Corporation, Kerosene oil and trading outlets in other parts of this State and also in the neighbouring State i.e. Punjab at Pathankot. Appellant is assessed to income tax. Appellant is maintaining separate books of accounts in respect of industrial undertaking i.e. oil mill unit, Damtal and all other respective business carried out at different places within and outside the State of Himachal Pradesh.