N.K.Sud, J.

1. This order will dispose of four appeals, viz., I. T. A. Nos. 6, 7, 119 and 120 of 2003, involving common questions of law and fact.

2. These appeals have been filed by the assessee-company against the order of the Income-tax Appellate Tribunal, Chandigarh Bench, Chandigarh (for short "the Tribunal"), dated June 20, 2002, for the assessment years 1990-91 and 1991-92. Although in the memorandum of appeals findings of the Tribunal on several issues have been questioned, but at the time of arguments counsel for the appellant confined his challenge to the finding whereby disallowance out of interest made by the Assessing Officer has been sustained. During the course of proceedings for the assessment year 1990-91, the Assessing Officer observed that the assessee had diverted huge amounts to M/s. S. A. B. Credits Limited, a company under the same management. He further observed that during the year under assessment, a sum of Rs. 82 lakhs had been advanced out of the cash credit account of the assessee-company in which there was a huge debit balance. He, therefore, held that since the assessee had diverted its borrowed funds to a sister concern without charging any i