SUDHIR AGARWAL,J. - (1.) Instant appeals have been preferred by Income Tax Department (herein after referred to "Revenue") under Section 260A of Income Tax Act, 1961 (herein after referred to as "Act, 1961") arising from a common judgment and order dated 29.08.2014 passed by Income Tax Appellate Tribunal, Allahabad Bench, Allahabad (herein after referred to as "Tribunal") relating to different Assessment Years (herein after referred to as "A.Y."). Details of appeals are given in the following chart: Sl. No. I.T.A. Number Assessment Year I.T.A.T. Number 1 125 of 2015 2001-02 360/ALLD/2014 2 126 of 2015 2003-04 362/ALLD/2014 3 127 of 2015 2004-05 363/ALLD/2014 4 128 of 2015 2005-06 364/ALLD/2014
(2.) Though appellants have formulated six substantial questions of law, but after some arguments, we find following three substantial questions of law arising in these appeals. Learned counsel for parties have also agreed and addressed us on these substantial questions of law:- (I). Whether order dated 25.03.2014 passed by C.I.T. under Section 263 of Act, 1961 was beyond its jurisdiction, in the facts and circumstances discussed by Tribunal, and whether it (Tribunal) was justified in holding so; (II). Whether Assessing Authority could have examined applicability of Sections 11 and 12 when Trust or Institution is already granted registration under Section 12A after following procedure laid down under Section 12AA of Act, 1961; and (III). Whether Tribunal was justified in holding that applicability of Sections 11 to 13 was to be governed by C.I.T. (A)'s order dated 21.11.2013, which was passed in appeal against order dated 28.12.2010 and that being so, order dated 01.12.2001 passed by Assessing Authority was in the same line, hence C.I.T. had no jurisdiction to pass order under Section 263 of Act, 1961 questioning applicability of Sections 11 to 13 in the case in hand.
(3.) Before dealing with aforesaid questions on merits, it would be useful to have a bird-eye view of relevant facts, giving rise to present dispute.;