Ashok Bhan, J.

1. This order shall dispose of ITRC Nos. 30-31 of 1995, ITRC Nos. 32-33 of 1995, ITRC Nos. 34-35 of 1995 and ITRC Nos. 36-37 of 1995, arising from the order of the Income-tax Appellate Tribunal (hereinafter referred to as "the Tribunal"), dated June 15, 1993, relating to the assessment years 1985-86, 1986-87, 1988-89 and 1989-90. The Revenue as well as the assessee have claimed one question each in all the assessment years thereby giving rise to eight reference petitions. The Tribunal has disposed of eight appeals relating to the four assessment years by passing one order as the facts and the questions of law involved are the same. Since common issues arise for consideration arising from the same facts in all these petitions, we also dispose of them by a consolidated order for the sake of convenience.

2. The trust styled "the Indian Telephone Industries Employees' Death and Superannuation Relief Fund" was created by a deed dated December 19, 1983, by the employees of the Indian Telephone Industries called the settlers for the benefit of about 20,000 employees of ITI in various towns in the country. Copy of the trust deed along with its rules were placed on rec