N.P.GUPTA, J. - (1.) THESE four appeals arise in identical circumstances, basically involving a common question, though one question as involved in three appeals is not incorporated in Appeal No. 13, however, in view of the controversy involved in all the four matters, we think it appropriate to decide all these four appeals by this common judgment.
(2.) APPEALS No. 70, 50 and 23 have been admitted on different dates, by framing following two substantial questions of law, which are common in all the three matters, being as under: i) Whether, on the facts and circumstances of the case the ITAT was justified in holding that the assumption of jurisdiction under Section 147/148 of the Income Tax Act is bad in law and accordingly in quashing the reassessment proceedings? ii) Whether on the facts and circumstances of the case the ITAT was justified in holding that the assessee is entitled to get depreciation under Section 32 on the assets claimed to be taken on lease, as owner of the assets? Appeal No. 13 has been admitted on 13.03.2007, by framing following one substantial question of law, which happens to be question No. 2 in other three appeals: Whether on the facts and circumstances of the case the ITAT was justified in holding that the assessee is entitled to get depreciation Under Section 32 on the assets claimed to be taken on lease, as owner of the assets?
(3.) ALL these four appeals relate to different assessment years.;