( 1 ) THESE petitions are directed against an order of the Central Board of Direct Taxes dated 3. 5. 2000 (Annexure-K) and for a prayer to direct the Central Board of Direct Taxes to accord approval to the petitioner under Section 36 (1) (viii) of the Income Tax Act, 1961 (Act for short) for the assessment years 1995-96, 1996-97 and 1997-98.

( 2 ) PETITIONER, a limited company, carries on the business of proving long term finance for construction or purchase of houses in India for residential purposes. Petitioner commenced business during the end of 1994 and its first year of business ended on 31. 3. 1995. Petitioner has filed a Memorandum and Articles of Association in terms of Annexure-A with regard to its business of providing long term finance for construction or purchase of houses in India for residential purposes.

( 3 ) THE Income Tax Act provides for substantial concession in terms of Section 36 (1) (viii) of the Act with regard to special reserve created and maintained by a public limited company founded and registered in India with the object of carrying on the business of providing long term finance for construction or purchase of houses. The said section provides for app

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