Sanjiv Khanna, J. - (1.) The aforestated appeals under Section 260A of Income Tax Act, 1961 (Act for short) filed by M/s Ram Krishan Associates Private Limited pertain to assessment years 1994-95 and 1996-1997 to 1997-1998 and arise from order dated 14.05.2004 in I.T.A. No.3636/Del/2000, 23.06.2004 in I.T.A. No.869/02 and 20.04.2003 in ITA No. 873/2002 passed by the Income Tax Appellate Tribunal.
(2.) The appeals were admitted for hearing vide order dated 08.12.2006 on the following substantial questions of law:- 1. Whether a person though a Licensee but has exclusive rights over a property is not owner for the purposes of Section 22 of the Income Tax Act, 1961? 2. Whether the appellant was/is entitled to 1/5th statutory deduction as claimed in view of various provisions as enshrined U/S 22 to 27 and 269UA of Income Tax or would it constitute income from other sources?
(3.) To avoid prolixity we are not referring to assessment and appellate orders. We would note the relevant undisputed facts as held and found by the Tribunal.;