Maniula Chellur, C.J.

1. In all the above appeals since common questions of law are involved, they are heard and disposed of together. The following substantial questions of law arise for consideration in these appeals:

"1. Whether the Income Tax Appellate Tribunal was correct in holding that appellants/assessees were not entitled to deduction of 10% of the aggregate average advances made by its rural branches under Section 36(l)(viia) of Income Tax Act?

2. Whether on the facts and in the circumstances of the above cases, Income Tax Appellate Tribunal was correct in holding that definition of rural branch in Explanation (ia) to Section 36(l)(viia) is applicable to Co-operative Banks?

3. Whether on the facts and in the circumstances of the above cases, Income Tax Appellate Tribunal was correct in holding that definition of the term banking company in Section 5(c) of Banking Regulation Act covers a Cooperative Bank, which is separately defined in Section 5(cci) of the said Act?"

2. All the above appeals are directed against th* order of the Appellate Tribunal. It is clear from substantial questions of law stated above what exactly is the dispute. Admittedly, appellants/ass