A.K.SIKRI,J. - (1.) Leave granted.
(2.) All these four appeals are filed by the Commissioner of Income Tax-III, Pune (hereinafter referred to as the 'Revenue), wherein the respondent is also the same (hereinafter referred to as the 'assessee'). Even the issue that arises for consideration is identical in all these appeals. Reason for filing four appeals is that the dispute pertains to four Assessment Years, i.e. 2000-01, 2001-02, 2002-03 and 2003-04. In fact, for this very reason the High Court has decided the issue by common judgment dated March 25, 2015, the correctness whereof is challenged by the Revenue in these appeals. Thus, we propose to club all these appeals and proceed to decide by a singular judgment.
(3.) The issue pertains to the validity of the proceedings which were initiated by the Assessing Officer (for short, 'AO') under Section 153C of the Income Tax Act, 1961 (hereinafter referred to as the 'Act'). It may be mentioned here itself that the assessee is an educational institution registered under the Bombay Public Trusts Act, 1950 and the Societies Registration Act, 1860. It also got itself registered under Section 12AA of the Act since the Assessment Year 1994-95. Because of the said registration under Section 12AA of the Act, Sections 11 and 12 of the Act apply to the assessee as per which income earned by the assessee from property held for charitable or religious purposes (Section 11) and income from contributions are exempt from taxation under certain circumstances.;