( 1 ). This common order shall govern the disposal of three writ petitions between the same parties and arising out of a common set of facts and events.

( 2 ). The petitioner is a public limited company engaged in the business of manufacturing of photo sensitive film and is a regular income tax assessee since long. It commenced several industrial units, one of which is located at an industrially backward area of Bhimtal in Nanital District of the State of U. P. The unit was engaged in manufacturing of colour roll films.

2. 1 Prior to the assessment year 1991-92 the asessee had claimed investment allowance under Section 32a of the Income-tax Act, 1961 on the machines installed for production of colour film rolls for the period relevant to the assessment year 1990-91. This claim of the petitioner was disallowed by the assessing officer on the ground that manufacture of colour film rolls was not entitled to investment allowance because such an article was included in the prohibited list mentioned in the Eleventh Schedule of the Income-tax Act, 1961. In the said list, at Sl No. 10 the articles mentioned are : "photographic apparatus and goods". The cinematographic film