Sanjiv Khanna, J.

1. Revenue has preferred these two appeals under Section 260A of the Income Tax Act, 1961 (Act, for short) in the case of Kelvinator of India Ltd. (now known as Whirlpool India Ltd.). These appeals pertain to assessment years 1989-90 and 1990-91. The order impugned, common to both appeals, passed by the Income Tax Appellate Tribunal (Tribunal, for short) is dated 30th August, 2000.

2. By order dated 6th December, 2001, the following substantial questions of law were framed:-

ITA 170/2001 (Assessment Year 1989-90)

“(A) Whether ITAT is correct in law in deleting the addition of Rs.7,28,400/- being the guest house expenses relying on its earlier order when the same are not accepted by the Department and the same expenditure is clearly disallowable u/s 37(4) of the Act?

(B) Whether ITAT was correct in law in taking into consideration interest on FDR, Misc. Receipts and interest from customers on delayed payments for the purpose of Section 80-I of the Act?

(C) Whether ITAT was correct in law in holding that the deduction u/s. 32AB was available on the profits