Commissioner Of Income Tax, Kanpur – Appellant
Versus
Kamla Town Trust – Respondent
ORDER
S. B. Majmudar, J.
1. In this group of 17 appeals by special leave, the Commissioner of Income-tax, Kanpur has brought in challenge the judgment and order dated 20th February, 1975 of the Allahabad High Court in Income-tax References Nos. 18 of 1973 and 715 of 1972 (reported in 1975 Tax LR 829). Respondent--Kamla Town Trust--is the common respondent in all these appeals. As common questions of law and fact are involved between the very same parties in all these appeals, the appeals were heard together and are being disposed of by this common judgment.
2. The common respondent, Kamla Towm Trust, was assessed to income-tax for the relevant assessment years 1949-50 to 1965-66. These assessment orders gave rise to hierarchy of appeals under the Income-tax Act which ultimately culminated into 17 income-tax appeals by the assessee before the Income-tax Appellate Tribunal, Allahabad Bench, Allahabad. The common question in the appeals before the Tribunal was whether for the relevant assessment years the respondent-assessee was entitled to exemption from payment of income-tax as per the provisions of Section 4(3)(i) of the Income-tax Act, 1922 (hereinafter referred to as the 1922 Act),
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