Hon’ble Tarun Agarwala, J.—The present appeals relate to the assessment years 2003-04 and 2004-05. All the appeals involve the same question of law and are being disposed of by a common order. All the appellants are co-owners of a land situate at khasra No. 634 at village Artoni, Mathura Road, Agra. The land was mortgaged with State Bank of India, Agra, for the loan taken by the firm M/s Mehra Off Set Press in which the assessees were partners. On account of the non-payment of the outstanding dues, the Bank filed a civil suit for recovery of the amount and pendente lite interest. The suit was subsequently transferred to the Debt Recovery Tribunal. During the pendency of the proceedings, One Time Settlement was arrived at, on the basis of which, the assessees negotiated and entered into an agreement on 4.7.2001 with subsequent purchaser to sell the land at Rs. 34,71,750/- per hectare. In furtherance of the said agreement, the assessees received part consideration through which the liabilities of the State Bank of India were cleared and upon receiving the payment the Bank lifted the encumbrances and released the mortgaged property on 21.11.2001. The sale-deed was eventually