M.S. Sanklecha, J.

These three Appeals under Section 260-A of the Income Tax Act, 1961 (the Act), challenge the two orders of the Income Tax Appellate Tribunal (the Tribunal) dated 26th September, 2012 and 16th September, 2015. The impugned order dated 26th September, 2012 relates to Assessment Year 2007-08 being Income Tax Appeal No.1179 of 2013. The impugned order dated 16th September, 2015 is a common order of the Tribunal, relating to Assessment Years 2004-05 and 2006-07. Thus the two appeals being Income Tax Appeal No.1321 of 2016 and 1322 of 2016 are in respect of Assessment Year 2006-07 and 2004-05 respectively.

2. On 12th February, 2019, Income Tax Appeal No.1322 of 2016 relating to Assessment Year 2004-05 was on board for admission. The following questions of law were urged in the appeal for our consideration :-

"(a) Whether on the facts and in the circumstances of the case and in law, the Tribunal justified in confirming the order of the CIT(A) and directing the AO to allow exemption u/s. 10(23C) (iiiab) of the Act without appreciating the fact that the assessee is not wholly or substantially financed by the Govt. in view of explanation to sub section (1) of sectio