ORDER :

1. Leave granted in all the Special Leave Petitions.

2. The Assessment Years in question are 1999-2000, 2000-2001 and 2001-2002. The point involved in the present appeals is short and precise. The subvention received by the Assessee-Company from its parent Company in Germany in a situation where Assessee- Company was making losses has been treated to be a revenue receipt by the Assessing Officer. Though the First Appellate Authority - Commissioner of Income Tax (Appeals) and the learned Income Tax Appellate Tribunal ("Tribunal" for short) has reversed the said finding, the High Court, by the orders under challenge, has restored the view taken by the Assessing Officer. Aggrieved the Assessee has filed the present appeals.

3. The question of law that was presented before the High Court, namely, whether subvention was capital or revenue receipt, was sought to be answered by the High Court by making a reference to two decisions of this Court in Sahney Steel & Press Works Ltd. Hyderabad vs. Commissioner of Income Tax, Hyderabad, (1997) 7 SCC 764 and Commissioner of Income Tax, Madras vs. Ponni Sugars and Chemicals Limited, (2008) 9 SCC 337. The view expressed by this Court that unl