JUDGMENT :

M.R. SHAH, J.

1. Feeling aggrieved and dissatisfied with the impugned common judgment and order dated 08.08.2017 passed by the High Court of Judicature at Bombay in Writ Petition No. 1432/2017 and Writ Petition No. 1406/2017, by which the High Court has dismissed the aforesaid writ petitions preferred by the Commissioner of Income Tax (IT-4), Mumbai (hereinafter referred to as the ‘Revenue’) and has confirmed the order passed by the Income Tax Appellate Tribunal, Bench at Mumbai (hereinafter referred to as the ‘ITAT’) dated 18.11.2016 passed in Miscellaneous Application Nos. 261/M/2014 and 419/M/2013, by which the ITAT in exercise of powers under Section 254(2) of the Income Tax Act (hereinafter referred to as the ‘Act’) has recalled its earlier order dated 06.09.2013 passed in ITA No. 5096/Mum/2008 and ITA No. 837/Mum/2007, the Revenue has preferred the present appeals.

2. The facts leading to the present appeals in a nutshell are as under. For the sake of convenience, the facts in Civil Appeal No. 7110 of 2021 arising from Special Leave Petition (Civil) No. 13963/2018 in the case of M/s Reliance Telecom Limited (hereinafter referred to as the ‘Assessee’) are narrated. The