Paripoornan, J. - (1.) Special leave granted in S.L.P. Nos. 15006-15008 of 1992.
(2.) The revenue represented by the Commissioner of Income-tax, Gujarat at Ahmedabad, is the appellant in this batch of 10 cases. The respondents are different assessees to Income-tax.
(3.) The revenue has filed the appeals from different orders passed by the High Court of Gujarat, rejecting the applications filed by the revenue under Section 256(2) of the Income-tax Act, 1961. The question formulated by the revenue in different cases are specified herein-below: C.A. No. 3180/92 "Whether, the Appellate Tribunal is right in law and on facts in holding that while computing long term capital gains and sale of shares, the bonus shares ought to have been valued at average cost for the purposes of computing the cost of acquisition - C.A. No. 3358/92 "WHETHER, the Appellate Tribunal is right in law and on facts in directing the I.T.O. to take average price of bonus shares for computation of capital gains in respect of sale of 530 equity shares of Sarangpur Cotton Mfg. Co. Ltd., without reducing the cost price on receipt of bonus shares - C.A. No. 4635/92 "WHETHER, the Appellate Tribunal is right in law and on facts in directing the I.T.O. to take the average price of bonus shares for computation of capital gains in respect of sale of 716 equity shares of Sarangpur Cotton Mfg. Co. Ltd. without reducing the cost of original shares on averaging the cost price on receipt of bonus shares - C.A. No. 4238/92 "WHETHER the Appellate Tribunal is right in law and on facts in directing the I.T.O. to take the average price of bonus shares for computation of capital gains in respect of sale of 1633 equity shares of Sarangpur Cotton Mfg. Co. Ltd. without reducing the cost price on receipt of bonus shares - C.A. No. 4636/92 "Whether the Appellate Tribunal is right in law and on the facts in directing the I.T.O. to take the average price of bonus shares for computation of capital gains in respect of sale of 660 equity shares of Sarangpur Cotton Mfg. Co. Ltd. without reducing the cost price on receipt of bonus shares - C.A. Nos. 1664-65 (NT) of 1994 "Whether the Court below were right in law and on facts, in holding that the cost of original shares should be taken either at the cost price or at the substitute price as on 1-1-64 - C.A. Nos. 12531-33 of 1996 (@ S.L.P. Nos. 15006-08 of 1992) "Whether the Appellate Tribunal is right in law and on facts in directing the Income-tax Officer to take the average price of bonus shares for computation of capital gain in respect of sale of 414 equity shares of Sarangpur Cotton Manufacturing Co. Ltd. without reducing the cost of original shares on, averaging the cost price on receipt of bonus shares " ;