CHITRA VENKATARAMAN, J.

1. The assessee has filed the above appeals as against the order of the Income Tax Appellate Tribunal for the assessment years 1995-96 and 1996-97. The T.C.(A).No. 1150 of 2006 was admitted on the following substantial questions of law:-

"(i) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in holding that the interest under Section 234B is leviable even if there was no liability to pay advance tax is fastened on assessee, since at the due dates of payment of advance tax, the assessee was incurring losses and could not have comprehended taxable income at a later date?

2. Whether on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the levy of interest under Section 234B is consequential?. "

2. The T.C.(A).Nos. 1151 and 1152 of 2006 were admitted on the following substantial questions of law:-

"(i) Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in upholding the addition of Rs.86,50,250/- as receipt of on money transaction?

(ii) Whether on the facts and in the circumstances