S.C. DHARMADHIKARI, J.

1. By these appeals, the Revenue has proposed common questions and stated to be substantial questions of law.

2. These questions are set out at pages 14 and 15 of the paper-book in Income Tax Appeal No.1315 of 2015.

3. These questions and the additional question stated to be of law are common to both these appeals.

4. It would be convenient to take the facts from Income Tax Appeal No.1315 of 2015. Therein the Revenue challenges the order passed on 10-12-2014 by the Income Tax Appellate Tribunal, Mumbai for the Assessment Year 2008-09. The Tribunal has dismissed the Revenue's appeal.

5. This Court's jurisdiction under Section 260A of the Income Tax Act, 1961 ("the I.T. Act" for short) is invoked in the following facts and circumstances.

6. The assessee before this Court is a Private Limited Company. It is carrying on business as a Third Party Administrator ("TPA" for short). The assessee is holding a licence from the Insurance Regulatory and Development Authority ("IRDA" for short). The Revenue claims that the assessee is appointed by various insurance companies to disburse amounts under what is styled as Mediclaim Insurance Policy. The insurance companies is