Manjula Chellur, J.

In all the above appeals since the 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 per cent of the aggregate average advances made by its rural branches under section 36(1)(viia) of the Income-tax Act, 1961 ?

2. Whether, on the facts and in the circumstances of the above cases, the Income-tax Appellate Tribunal was correct in holding that the definition of rural branch in Explanation (ia) to section 36(1)(viia) is applicable to co-operative banks ?

3. Whether, on the facts and in the circumstances of the above cases, the Income-tax Appellate Tribunal was correct in holding that the definition of the term 'banking company' in section 5(c) of the Banking Regulation Act covers a co-operative bank, which is separately defined in section 5(cci) of the said Act ?

2. All the above appeals are directed against the order of the Appellate Tribunal. It is clear from substantial questions of law stated above what exactly is