1. As all these appeals filed by the Revenue arise out of a common order dated 30.09.2019 of the Income Tax Appellate Tribunal [hereinafter referred to as the ‘Tribunal’] Cochin Bench, they are taken up for consideration together and disposed by this common judgment. For the sake of convenience, the details of the various appeals with reference to the assessee and the assessment year concerned, as also co-relating it to the appeals that were filed before the Tribunal, are provided in tabular form below:

2. The brief facts necessary for disposal of these appeals are as follows:

The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering and Management. The 12 trustees of the Trust belong to three closely related family groups, and their details are as follows:

(1) Sri. Babu P. Thomas, his wife Smt.Gracy Babu and their two major sons.

(2) Sri. Jose Thomas, his wife Smt. Reena Jose and their major son and daughter.

(3) Sri. P.J. Paulose, his wife Smt. Lizzy Paulose and their two major daughters.

Due to difficulties in managing the College, and also due to the personal differences, the trustees decided to discontinue the business and entered into an agreement with the Believers Church on 10.03.2009, whereby, all the existing trustees resigned from their trusteeship and simultaneously, new trustees nominated by the Believers Church were inducted. The agreement between the parties also provided for payment of Rs. 37.5 crores to the erstwhile trustees for settling their liabilities as well as completing certain construction activities that had been commenced by them prior to the agreement. The agreement also provided for sale of 55.15 acres of land belonging to some of the erstwhile trustees for a consideration of Rs. 12.50 crores.

3. A search under Section 132 of the INCOME TAX ACT [hereinafter referred to as the “I.T. Act”] was conducted at the residence of the Sri.Jose Thomas, Smt.Gracy Babu and Sri. P.J. Paulose on 04.03.2009 and certain documents were seized. An unsigned draft agreement dated 23.02.2009 was found which indicated that the amount envisaged for settlement of liability was Rs. 43.50 crores and that the value of the rubber estate extending to 55.15 acres of land was Rs. 6.50 crores. Certain other documents relating to fee collection from students in excess of what was fixed by the Government, and investment details of trustees etc. were also seized, but those particulars are not of any concern to us in these appeals.

4. Assessments were completed under Section 14 3(3) read with Section 153A for the assessment years 2003-04 to 2008-09 and under Section 14 3(3) for the assessment year 2009-10 in relation to the persons who we