(1.) The present appeals are directed against 1 the common order dated October 15, 2012 passed by the Income-tax Appellate Tribunal, Amritsar Bench at Amritsar in respect of assessment year 2008-09.1. T. A. No. 2/2013 is in respect of I.T.A. No. 102(Asr)/2012 which was an appeal filed by the assessee before the Tribunal. I.T.A. No. 3/2013 is in respect of I.T.A. No. 127(Asr)/2012 which was an appeal preferred by the Department before the Tribunal.
(2.) On July 3, 2013, when the present appeals were admitted to hearing, the following substantial questions of law were framed for consideration of this court :
(3.) In that order itself, it was however recorded that it will be open for the assessee to argue that no substantial question of law had arisen. That is exactly what the learned counsel for the assessee has done before us.